Blogs

WTW’s three-part series on the implementation of the forthcoming clawback listing standards prompted by the new Dodd-Frank-triggered SEC rule covers the gamut of to-dos and considerations in preparation for compliance. 

• Part 1 in the series: “A game plan for harmonizing your holdback and clawback policies” addresses how to inventory current potentially relevant clawback and holdback provisions.
• Par 2 in the series: “Conduct a detailed inventory of each element of officer pay” provides guidance on how to determine the compensation that is subject to clawback.
• Part 3 in the series: “Exploring the source of funds for exercising a clawback” discusses the sources of funds companies may consider to enforce a clawback; consideration of a framework that outlines sources of funds in order of priority/easiest access; and considerations relative to former officers.

See our recent report: “Clawback Policy Considerations” and additional resources on our Clawbacks page.
           
                      This post first appeared in the weekly Society Alert!