Foley Partner and chair of the Transactional & Securities Practice Jay Rothman was quoted in an article titled “Checking On Risky Pay” in the December 18, 2009 issue of CFO. Rothman discusses the Securities and Exchange Commission’s expanded proxy disclosure requirements for companies with risky bonus plans, predicting that there will be clawbacks that would apply for less-than stellar performance in subsequent years, rather than simply for financial restatements. He adds that the good news is that the burden of the disclosure requirements will be very industry-dependent.
