As we discussed in this blog post, as part of implementing the Dodd-Frank clawback provisions, the SEC required the NYSE and NASDAQ to adopt appropriate clawback listing standards.

On June 9, 2023, the SEC approved the NYSE’s and NASDAQ’s clawback listing standards, which will be effective on October 2, 2023.  Companies listed on the NYSE and NASDAQ will be required to adopt appropriate clawback policies by December 1, 2023.  These policies will apply to any incentive-based compensation paid after October 2, 2023.

As always, your thoughts and comments are welcome.