SEC Proposes Compensation Clawback Rules

This article address rules proposed by the SEC on July 1, 2015, to implement the “clawback” policy enacted by Section 954 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The proposed rules would require publicly traded companies, if they correct prior financial statements, to recover (i.e. clawback) from their executive officers previously paid incentive based compensation to the extent it was greater than what would have been paid under the corrected financial statements for the preceding three fiscal years.