“Six Steps for Adhering to the SEC’s New Clawback Rule” from Farient Advisors compares common voluntarily adopted clawback policy provisions to like provisions of the final SEC rule to assist those companies that already have a clawback policy in place (95% of the S&P 500; 60% of Russell 3000 companies exclusive of the S&P 500) in identifying and—at a minimum—closing the gaps.
Companies that have not yet adopted a clawback policy are advised to think outside the (rule)box in developing one, i.e., consider whether a more expansive policy than that which will be required by law may be warranted or beneficial in response to investor and proxy advisor expectations.
Regardless of current positioning, the briefing offers a series of action items for all covered listed companies to promote compliance with the listing standards by the expected effective dates.
See our recent reports: “SEC Clawback Rules: Important Dates” and “SEC Adopts Final Clawback Rules” and additional information & resources on our Clawbacks page.
This post first appeared in today's weekly Society Alert!