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SEC Adopts Final Pay Versus Performance Rules

McDermott Will & Emery Employee Benefits

On August 25, 2022, the US Securities and Exchange Commission (SEC) adopted final rules to implement the pay versus performance disclosure requirement mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).

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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.