Guide to the 10-K Clawback Checkboxes

Cooley has published a new resource – Guide to the 10-K Clawback Checkboxes – to help guide companies through the statutory and regulatory requirements for the Form 10-K clawback checkboxes.

The Form 10-K checkboxes disclosing clawbacks have caused considerable confusion since the rules were adopted. Recently, the Securities and Exchange Commission published six compliance and disclosure interpretations (C&DIs) on the checkboxes to help companies analyze when the checkboxes need to be checked and if related proxy disclosure is required. This new resource helps guide companies through the analysis in an easy-to-follow flowchart format.

For additional information on the clawback checkboxes and C&DIs, check out this blog post and this set of FAQs on Cooley’s Governance Beat blog.

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