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Index/Topics/Federal Enforcement Guidance

Federal Enforcement Guidance

Federal guidance encouraging clawbacks while recognizing practical limits.

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1 result
Feb 5, 2026

What alternative retention structures (vesting, forgivable loans) have agencies used to avoid clawback litigation?

Employers and public agencies have shifted from upfront “repay-if-you-leave” toward a toolbox of alternatives — deferred payouts, vesting schedules, performance-based pay, prorated repayment mechanics...

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