REITs Executive Compensation Guide

PRACTICE POINT: Although final adoption of listing standards relating to clawback policies likely will not become effective until late 2023, issuers should proactively revisit their existing clawback policy, if any, or start working on a draft policies that will comply with the new rules. As an initial matter, issuers should discuss the new rules with their compensation committees, assess their existing incentive-based compensation programs and determine what “financial reporting measures” are tied to incentive compensation awards.

2023 Guide to REIT Executive Compensation | 6