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Legal Update

US Securities and Exchange Commission Proposes Compensation Clawback Listing Standards Requirement

16 July 2015
Mayer Brown Legal Update
As required by the Dodd-Frank Wall Street Reform and Consumer Protection Act, the US Securities and Exchange Commission has proposed new Rule 10D-1, directing national securities exchanges and associations to establish listing standards that prohibit the listing of any security of a company that does not adopt and implement a written policy requiring the recovery, or “clawback,” of certain incentive-based executive compensation. The proposal also specifies disclosure requirements relating to clawback policies and clawbacks. The SEC’s proposing release raises many complex issues that merit attention and further discussion, and the SEC has expressly requested comments on more than 100 specific questions. Comments are due by September 14, 2015.


  • Laura D. Richman
    T +1 312 701 7304
  • Robert F. Gray, Jr.
    T +1 713 238 2600
  • Michael L. Hermsen
    T +1 312 701 7960
  • Ryan J. Liebl
    T +1 312 701 8392
  • David A. Schuette
    T +1 312 701 7363
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