On June 8, 2022, the SEC issued a release reopening the comment period for the clawback rules initially proposed in July 2015 to implement the provisions of Section 954 of the Dodd-Frank Act. The 2015 proposed rules would require securities exchanges to establish listing standards that would require public companies to develop, implement and disclose a clawback policy. This reopening release follows on the heels of the SEC’s October 2021 reopening of the comment period for the proposed rules, which closed on November 22, 2021. Last week’s re-reopening of the comment period is intended to allow interested persons to comment on the additional analysis and data provided in a memo from the SEC’s Division of Economic and Risk Analysis (“DERA”). READ MORE