Part 1: The SEC's Dodd-Frank Clawback Proposal

It's too little, too complicated, and too late. Is the SEC just pulling our chain?

There is something in the pang of change,

More than the heart can bear,

Unhappiness remembering happiness. Euripides

Today is Part 1 where I will describe the SEC’s Dodd-Frank Sec. 954 clawback proposal, the reopened comment request and some of the history surrounding this rulemaking. In Part 2 and Part 3, I will discuss what we can learn from the past a…