Executive Summary Writing a clawback policy was a compliance exercise. Using one is a different job entirely. Under SEC Rule 10D-1, companies listed on US exchanges have to recover erroneously awarded compensation from executives when an accounting restatement is required. On paper, that's a tidy rule. In real life the restatement shows up late, the numbers keep shifting, and a board is suddenly asking whether three years of bonuses were ever really earned. This post covers w