NYSE and Nasdaq Propose Clawback Listing Standards

On March 2, 2023, Cravath prepared a memo for its clients entitled “NYSE and Nasdaq Propose Clawback Listing Standards.” The memo examines the New York Stock Exchange and Nasdaq Stock Market’s proposed rules in response to the SEC’s adoption of final rules implementing the clawback provisions of the Dodd-Frank Act. The exchanges’ proposed rules establish listing standards requiring listed companies to implement a clawback policy and outline what could occur if a listed company fails to adopt or comply with its policy. In addition to summarizing these standards, the memo outlines the public comment period, and suggested next steps for affected companies.

Please click here to read the memo.