On Friday, the SEC posted these four C&DIs on the new clawback rule addressing the presence of compliance checkboxes on Form 10-K, 20-F, and 40-F in advance of the adoption of the relevant listing standards (Question 121H.01); identification of NEOs for purposes of Form 20-F and 40-F disclosure (Questions 121H.02 and 121H.03, respectively); and the broad applicability of the rule to incentive-based compensation plans, which may include, e.g., long term disability plans, life insurance plans, or SERPs (Question 121H.04).
Access additional resources on our Clawbacks page.