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Division of Corporate Finance

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On April 11, 2025, the US Securities Commission’s Division of Corporation Finance issued six new Compliance and Disclosure Interpretations (CDIs) that provide guidance on the disclosures required when a US listed issuer has an accounting restatement that may trigger a clawback of “erroneously-awarded compensation” under Exchange Act Rule 10D-1 and the corresponding listing standards. See Exchange Act Forms CDIs 104.20 – 104.25, as linked below. When to Mark Check Boxes on Annual Reports The new…