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EXECUTIVE COMPENSATION

HR Management Activities

On average, salaries make up about 40— 60% of the typical top executive’s annual compensation total. A provision of a 1993 tax act prohibits a publicly traded company from deducting pay of more than $1 million for each of its top five officers unless that pay is based on performance criteria approved by outside directors and shareholders.

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Long Time Coming: SEC Adopts Final Dodd-Frank Clawback Rules

Proskauer's Employee Benefits & Executive Compensa

Twelve years after the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act, and many years after the Securities and Exchange Commission started considering regulations implementing the clawback provisions of Dodd-Frank, the SEC published the Final “Clawback” Rules (the “Final Rules”) on October 26, 2022.