SEC Commissioner Peirce on Flaws in New Clawback Rules
Reynolds Holding
OCTOBER 27, 2022
Special thanks go to Luna Bloom, Steven Hearne, Brian Galle, and Jessica Barberich for answering my many questions on the release, along with Lindsay McCord and Jonathan Wiggins for lots of time patiently discussing the fine points of “little r” restatements. Comment Letter from Davis Polk & Wardwell LLP at 2, Sept. ENDNOTES. [1]
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