Double jeopardy: three-year time bar on regulatory enforcement proceedings increased to six years
In March, we brought you news of the Prudential Regulation Authority’s (PRA’s) proposal to apply clawback to bonuses and other forms of variable remuneration for up to six years post vesting.
We highlighted numerous practical issues with the proposals, including how to manage its retrospective application and the requirement to amend employment contracts to allow for clawback.
One of the biggest stings in the clawback tail was that, in reality, given the lengthy vesting periods that apply to most variable pay awards — in some cases up to five years post grant — clawback could be applied for up to 11 years after the date on which a bonus or other variable incentive was first awarded…
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