Doreen Lilienfeld, head of Shearman & Sterling’s Compensation, Governance & ERISA practice, spoke with The Wall Street Journal about the proposed SEC rules to implement Section 954 of the Dodd-Frank Act.  The proposed rules would require all public companies to implement clawbacks of incentive-based compensation for a wider range of corporate executives in the event of an accounting error.  As discussed in Shearman & Sterling’s 2015 Corporate Governance and Executive Compensation Survey, while many companies voluntarily maintain clawback policies, almost all would need to rewrite their policies in order to comply with the new rules under Dodd-Frank.