New SEC compensation clawback rule - what's the impact on executive compensation?
Following the implementation of the rule, 103 companies noted that financial statements were corrected. One company indicated that a clawback might be required.
When SEC Rule 10D-1, which requires companies to claw back erroneously paid compensation after accounting corrections, went into effect on December 1, 2023, I predicted that we might see a post-implementation diversity in practice.
My preliminary analysis of roughly 3,500 10-K filings filed between January 1, 2024, and March 15, 2024, finds inconsistenci…