The SEC’s October 2022 Listing Standards for Recovery of Erroneously Awarded Compensation Final Rule requires national securities exchanges to propose and adopt requirements that listed companies have an appropriate “clawback policy.”  The NYSE and NASDAQ recently issued proposed listing standards.  You can find the proposals for the NYSE here and for the NASDAQ here.

You can read this post for more information about the clawback rulemaking process and deadlines.  The post also includes a clawback policy template from Gary Brown, Partner at Nelson Mullins Riley & Scarborough LLP, and SEC Institute workshop leader and PLI author.

You can read this post for information about the new clawback Form 10-K cover page checkboxes and other disclosures. 

As always, your thoughts and comments are welcome!