The SEC approved a new exchange listing standard for public companies required by the Dodd-Frank Wall Street Reform and Consumer Protection Act, which required listed companies to adopt a clawback policy by December 1, 2023. This policy requires the clawback of “incentive-based” compensation erroneously received by current and former executive officers, regardless of fault, during the three years prior to an accounting restatement. Although the legal requirements for a clawback policy are straightforward, the implementation of a clawback can be complicated. READ MORE