PwC comments on the SEC's Dodd Frank clawback proposal

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Comment letter , PwC US Sep 14, 2015

PwC supports the SEC's proposal, but offers recommendations intended to provide additional guidance on certain aspects.


PwC issued comments on the SEC’s proposal, Listing Standards for Recovery of Erroneously Awarded Compensation. PwC is supportive of the proposal and agrees with the Commission’s definition of the term accounting restatement, including the limitation of the proposed clawback to material restatements. We support the Commission’s proposal not to describe the type or characteristic of a material error for the purposes of the listing standards.

PwC has suggested certain clarifications, principally related to the accounting period in which the compensation to be recovered should be recorded, and that the proposed clawback would not impact the establishment of a grant date under FASB ASC 718, Compensation-Executive Compensation.

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Heather Horn

Heather Horn

US Strategic Thought Leader, National Professional Services Group, PwC US

David Schmid

David Schmid

International Accounting Leader, National Professional Services Group, PwC US

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