GC Email
Oct. 15, 2016
Jensen embodied in proposed Dodd-Frank rule
Proposed Rule 10D-1 directs national securities exchanges to prohibit the listing of any security of an issuer that does not have a compensation clawback policy that contains various specified criteria. By Neal Potischman and Sarah K. Solum
Neal A. Potischman
Partner
Davis, Polk & Wardwell LLP
Email: neal.potischman@davispolk.com
Harvard University Law School; Cambridge MA
Neal focuses on defending securities and other complex litigation matters.
The possibility that a C-level executive might have his or her compensation "clawed back" after engineering a financial fraud is not new. Many corporate officers, however, may not realize that they could be required to disgorge incentive compensation paid two to three years ago whenever someone else in their organization engages in conduct that triggers a restatement. A number of developments continue to wea...
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