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SEC Commissioner Peirce on Flaws in New Clawback Rules

Reynolds Holding

For this reason, the Proposed Rule would potentially put an issuer in the position of failing to comply with the applicable listing standard or governing local law.”). [15] 15] Comment Letter from ABA 2016 at 28. [16] 22, 2021, [link] (“[N]either stock price nor TSR is a financial reporting measure used in preparing financial statements.)