On October 14, 2021, the US Securities and Exchange Commission (SEC) issued a release reopening the comment period (Reopening Release) on the clawback listing standard rule that it proposed in 2015 (2015 Proposal). Interested parties may submit comments on any aspect of the 2015 Proposal, as well as on the additional requests for comments raised in the Reopening Release. The new comment period closes 30 days after publication of the Reopening Release in the Federal Register. This Legal Update provides background details on the 2015 Proposal, along with 10 multifaceted areas regarding additional requests for comments.
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