Title

SEC Decides Not to Pursue Clawback Actions Against Executives Who Reimbursed Company for Previously Paid Compensation
Client Memorandum

Created date

2/23/2016

In two recent cases, the SEC affirmatively decided not to bring clawback actions under Section 304 of the Sarbanes-Oxley Act (“SOX”) against executives who reimbursed their respective companies for compensation they received following the filing of misstated financial statements.