Foley Partner Roger Lane and Senior Counsel Courtney Worcester authored an article titled “Dodd-Frank’s Mandatory Executive Comp Clawback,” that appeared in The Deal on December 20, 2010. Lane and Worcester offer insight regarding the Dodd-Frank Wall Street Reform and Consumer Protection Act. The authors acknowledge that while the concept of ‘clawing back’ executive compensation is not new, this act goes well beyond previous requirements. They suggest companies begin evaluating their options now, assessing how their future incentive-based awards can best be structured and looking into how they can minimize their legal risks in implementing a clawback policy.
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