Jennifer S. Conway, Kyoko Takahashi Lin, Michael Kaplan, Joseph A. Hall and Ning Chiu

Davis Polk Discusses Dodd-Frank Clawback Rules’ Application to Subsidiary Issuers, Guarantors

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Each subsidiary issuing or guaranteeing a public company’s listed debt securities is itself subject to the clawback rules recently adopted by the NYSE and Nasdaq.

In October 2022, the SEC adopted the final clawback rule mandated by the Dodd-Frank Act …