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On July 1, 2015, nearly five years after the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Act”) was enacted, the Securities Exchange Commission (“SEC”), in a split vote of three to two, proposed rules to implement Section 954 of the Act. Section 954 requires companies to adopt and enforce a policy (a “recovery policy,” commonly referred to as a clawback policy) providing for repayment from executive officers of incentivebased compensation (“IBC”) when restated financial statements indicate there has been an overpayment.

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