Dodd-Frank Clawback Rules: Overview and Special Considerations

Shalom D. Huber Joseph M. Penko

On June 27, New York executive compensation and benefits partners Shalom Huber and Joe Penko presented the webinar “Dodd-Frank Clawback Rules: Overview and Special Considerations,” hosted by the New York State Bar Association. The discussion explored the timetable for approval of a Dodd-Frank-compliant clawback policy, the disclosure requirements under Form 10-K and Item 402(w) of Regulation S-K, compensation potentially subject to clawback, the intersections between a Dodd-Frank-compliant clawback policy and other corporate documents, and the use of acknowledgment forms.