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Executive Compensation Total Shareholder Return (TSR) Regulation S-K

Husch Blackwell LLP

Lessons from the First Year of Pay vs. Performance Disclosures

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As we approach the 2024 proxy season, companies are preparing for the second year of compliance with the pay vs. performance (PvP) disclosure required under Item 402(v) of Regulation S-K. As a reminder, under Item 402(v) of...more

BCLP

Review of Recent SEC Staff Comments on Pay Versus Performance Table

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As companies prepare for next proxy season, they should review SEC staff guidance on the pay vs. performance table. In addition to recent staff interpretations, as discussed in our October 2, 2023 post and February 22, 2023...more

Morrison & Foerster LLP

Preparing for the 2023 Proxy Season

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Public companies need to consider recent developments when preparing for the 2023 proxy and annual reporting season. We summarize key regulatory developments, recent guidance, important disclosure considerations and updates...more

Paul Hastings LLP

Long-awaited Pay v. Performance Rules Adopted

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Recently, the U.S. Securities and Exchange Commission (the “Commission”) adopted long anticipated final rules requiring registrants to disclose information regarding the relationship between the actual compensation paid to...more

Eversheds Sutherland (US) LLP

SEC adopts “Pay Versus Performance” disclosure rules

​​​​​​​On August 25, 2022, the Securities and Exchange Commission (the SEC) adopted new provisions under Item 402 of Regulation S-K, 17 CFR 229.402(v) (the "Pay Versus Performance Rule" or "New Item 402(v)") mandating certain...more

Amundsen Davis LLC

The SEC Adopts Pay-Versus-Performance Disclosure Requirements for Executive Compensation—Do They Relate to You?

Amundsen Davis LLC on

On August 25, 2022, the U.S. Securities and Exchange Commission (SEC) voted to adopt the “pay-versus-performance” rule, requiring publicly traded companies (except foreign private issuers, registered investment companies, and...more

Foley & Lardner LLP

Public Company Pay Versus Performance Rules May Affect Pay Practices

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On August 25, 2022, the Securities and Exchange Commission (SEC) adopted final pay-versus-performance disclosure rules for publicly traded companies. These rules will require three new disclosures in upcoming proxy and...more

Smith Anderson

SEC Adopts Final Pay-Versus-Performance Disclosure Rules

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​​​​​​​On August 25, 2022, the Securities and Exchange Commission (SEC) adopted final rules implementing the "pay-versus-performance" disclosure requirement called for under Section 953(a) of the Dodd-Frank Wall Street Reform...more

Goodwin

Frequently Asked Questions: Pay Versus Performance Final Rules

Goodwin on

The SEC published final rules in late August 2022 that will require new pay versus performance disclosure in 2023 proxy statements, as described in our recent client alert. These rules will require companies that are not...more

Benesch

SEC Adopts Pay Versus Performance Rule on Executive Compensation

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In the years following the banking and financial crisis of 2008, there was a particular focus by the media and lawmakers on CEOs and other executives collecting hundreds of millions of dollars in compensation. In response,...more

Dorsey & Whitney LLP

SEC Adopts Mandatory Pay-versus-Performance Disclosure for 2023 Proxy Statements

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​​​​​​​The Securities and Exchange Commission (the “SEC”) has adopted final rules requiring additional disclosures on the relationship between executive compensation and financial performance. SEC disclosure counsel should...more

Vinson & Elkins LLP

SEC Adopts Final “Pay Versus Performance” Rules

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On August 25, 2022, the Securities and Exchange Commission (the “SEC”) announced that it adopted a final rule requiring companies to disclose information that is intended to reflect the relationship between compensation paid...more

Sullivan & Worcester

SEC Adopts Pay Versus Performance Disclosure Rules

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On August 25, 2022, the Securities and Exchange Commission finally adopted amendments to its rules mandated by the Dodd-Frank Act in 2010 and first proposed in 2015 that will require public companies to disclose information...more

Womble Bond Dickinson

SEC Adopts Pay for Performance Rules

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​​​​​​​On August 25, the SEC adopted rules implementing the pay for performance disclosure mandated by the Dodd-Frank Act. The rules, originally proposed in 2015 and subject to a reopened comment period earlier this year,...more

McDermott Will & Emery

New SEC Rules Heighten Scrutiny Over Executive Pay

McDermott Will & Emery on

On August 25, 2022, the US Securities and Exchange Commission (SEC) adopted final rules imposing new mandatory “pay for performance” disclosures for most public companies (foreign private issuers, emerging growth companies...more

Cooley LLP

Alert: SEC Proposes Long-Awaited Compensation Clawback Rule

Cooley LLP on

On July 1, 2015, the SEC issued a proposal to implement the last of the compensation-related provisions of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act that remained untouched on the SEC's plate—Section...more

Stinson - Corporate & Securities Law Blog

SEC Proposes Clawback Rules—A Comprehensive Summary

The SEC has proposed new rules to implement Section 954 of the Dodd-Frank Act, which added Section 10D to the Securities Exchange Act of 1934. Section 10D requires the Commission to adopt rules directing the national...more

Cooley LLP

Blog: SEC Proposes Clawback Rules

Cooley LLP on

At an open meeting this morning, the SEC voted, three to two, to propose rules implementing Section 954 of Dodd-Frank, the clawback provision. Both Commissioners Gallagher and Piwowar voted against the proposal....more

Burns & Levinson LLP

SEC Proposes New Pay-Versus-Performance Disclosure Rules

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On April 29, 2015, the Securities and Exchange Commission (the “SEC”) proposed new rules that would require most publicly traded companies to describe in detail the relationship between their financial performance and their...more

Cooley LLP

Alert: SEC Proposes New Rules on Pay Versus Performance When "Compensation Actually Paid" is Not Compensation Actually Paid and...

Cooley LLP on

On April 29, 2015, the SEC voted to propose rules requiring public companies to disclose the relationship between compensation actually paid and company financial performance. The proposal comes almost five years after the...more

Holland & Knight LLP

SEC Proposes New Executive Pay Versus Company Performance Disclosure Rules

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On April 29, 2015, the Securities and Exchange Commission (SEC) voted 3 to 2 to propose rules related to the disclosure of information that shows the relationship between executive compensation and the financial performance...more

Stinson LLP

Pay Versus Performance Rules Proposed by Securities and Exchange Commission

Stinson LLP on

On April 29, 2015, the U.S. Securities and Exchange Commission (SEC) issued another proposed rule under the Dodd-Frank Act, this time with respect to the pay versus performance requirements of Section 953(a) of the Act. ...more

Akin Gump Strauss Hauer & Feld LLP

SEC Proposes Pay Versus Performance Disclosure Rules

On April 28, 2015, pursuant to the mandate in Section 953(a) of the Dodd-Frank Act, the Securities and Exchange Commission (SEC) proposed new rules that, if adopted, would require public companies to disclose in their...more

Bracewell LLP

SEC Proposes Rules for Pay for Performance Disclosure

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On April 29, 2015, the Securities and Exchange Commission proposed rules requiring companies to disclose the relationship of executive pay to performance as required by Section 953 of the Dodd-Frank Wall Street Reform and...more

Parker Poe Adams & Bernstein LLP

The New Pay-for-Performance Proposal – A Misstep by the SEC

The SEC last week finally proposed rules mandated by Dodd-Frank providing for disclosure of the relationship between compensation actually paid to executives and company financial performance. While it is important to...more

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