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"an accounting restatement due to material noncompliance" should be interpreted to include . 0000008851 00000 n /Metadata 5 0 R The only exempted issuers under the final rules are issuers of security futures products, standardized options, unit investment trust securities and certain registered investment company securities. The materiality determination requires the evaluation of both qualitative and quantitative factors, leading to a significant amount of management judgement, in some circumstances. The final rules may result in a shift in the balance of the total compensation provided to executive officers away from the types of incentive-based compensation awards that would be subject to the rules. Action items when accounting errors are identified. 19, >> Unlike "Big R" restatements that must be. Consistent with the SECs focus on gatekeepers, the Statement also encourage[s] ongoing attention, including audit committee participation and training, as needed, regarding the adequacy of and basis for a registrants ICFR effectiveness assessmentparticularly where there are close calls in the assessment of whether a deficiency is a significant deficiency (and only required to be reported to the audit committee) or a material weakness (required to be disclosed to investors).. False Companies and their auditors and audit committees are well advised to keep the observations noted above in mind when making and documenting SAB No. 0000070964 00000 n SEC Releases Final Rules Regarding Clawback Policies for Public Issuers In a change from the proposed rules, the final rules will not require recovery of incentive-based compensation in circumstances where (i) the compensation was received by a person before beginning service as a covered executive officer or (ii) if that person did not serve as an executive officer at any time during the three-year lookback period for which the clawback rules apply. 0000010464 00000 n 0000114498 00000 n endstream endobj 122 0 obj <>/Metadata 26 0 R/PageLayout/OneColumn/Pages 25 0 R/StructTreeRoot 28 0 R/Type/Catalog>> endobj 123 0 obj <>/Font<>/XObject<>>>/Rotate 0/StructParents 0/Type/Page>> endobj 124 0 obj <> endobj 125 0 obj <> endobj 126 0 obj <> endobj 127 0 obj <>stream