Partner Celia Soehner spoke with The National Law Journal about the US Securities and Exchange Commission’s clawback rule, which recently took effect and requires publicly traded companies to have policies in place for recovering incentive-based compensation paid to executives due to a financial reporting error.
“You don’t have to be a bad actor in order to have your compensation drawn into what the rules require,” Celia said. “You could be doing your job, but by virtue of the fact that you’re one of the enumerated executive officers that’s mandated by the final rule to be brought into the fold—your compensation would be at risk, essentially.”
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