Whether it is called excess or erroneously awarded, some compensation – at some point – that has been paid to executives may need to come back to the company. Dodd-Frank made a policy on this mandatory, and the SEC rulemaking on Section 954 of Dodd-Frank needs to be taken into account. Attend this session to engage in a discussion of what a policy might cover and what a policy needs to cover. Consider the choices and policy implications on this important topic with colleagues. Should policies be all-encompassing, or should recapture provisions be included in employment agreements and awards? What triggers the clawback? Who is covered by the policy? What are others doing and what do advisory firms think about clawback policies? Good questions for a great discussion at this session.