On July 1, 2015, the SEC proposed a rule implementing Section 954 of the Dodd-Frank Act.  The proposed rule directs the stock exchanges to adopt listing standards that would require listed issuers to adopt and comply with a written clawback policy to recover any excess incentive-based compensation erroneously paid to any current or former executive officer because of material non-compliance with financial reporting requirements that resulted in a financial restatement.

Read the Davis Polk memo on this proposal »