By December 1, 2023, all companies listed on the NYSE or Nasdaq must adopt clawback policies that comply with listing standards mandated by the SEC (the SEC Clawback Rules). This requirement to adopt new compliant clawback policies applies to all US-listed companies, including listed foreign private issuers (FPIs). Latham & Watkins attorneys have prepared this FAQ to offer practical advice for listed companies implementing compliant policies.
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