In a recent “Deep Quarry” newsletter, Olga Usvyatsky shares some recent trends in clawback-related disclosures. She notes that only two of the about 250 companies that “checked the box” in 2024 actually sought to clawback excess compensation following a restatement. She surveyed a sample of about 30 recovery analysis disclosures and found four broad justifications companies […]

Dodd-Frank Clawbacks: Commonly Cited Reasons for No Recoupment