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White & Case LLP

Key Considerations for the 2024 Annual Reporting and Proxy Season Part II: Proxy Statements

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Each year in our Annual Memo series, White & Case's Public Company Advisory Group provides practical insights on preparing Annual Reports on Form 10-Ks, Annual Meeting Proxy Statements and, for FPIs, the Annual Report on Form...more

Proskauer - Regulatory & Compliance

SEC Adopts New SPAC Rules

On January 24, 2024, the SEC adopted new rules that apply to SPAC transactions and the adopted rules largely track the agency’s proposals with some notable exceptions. The new rules will become effective 125 days after...more

A&O Shearman

Securities and Exchange Commission Adopts New Clawback Rule

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On October 26, 2022, the Securities and Exchange Commission (SEC) adopted a new rule requiring U.S. public companies to recoup, or “claw back,” certain erroneously awarded executive compensation....more

Fenwick & West LLP

The SEC's New Pay Versus Performance Rule: FAQ

Fenwick & West LLP on

1. What is the Pay Versus Performance Rule? See our Fenwick alert for a high-level overview of the Pay Versus Performance (PvP) Rule. See also the SEC fact sheet and adopting release. Briefly, the PvP Rule adds a new Item...more

Kramer Levin Naftalis & Frankel LLP

SEC Adopts Final Rule Requiring ‘Pay Versus Performance’ Disclosure

On Aug. 25, 2022, the Securities and Exchange Commission (SEC) adopted a new rule requiring public companies (subject to some notable exceptions, described below) to disclose, in proxy statements and information statements...more

Sheppard Mullin Richter & Hampton LLP

SEC Releases Pay Versus Performance Disclosure Requires For Public Companies

On August 25, 2022, the Securities and Exchange Commission adopted a pay versus performance rule in accordance with the Dodd-Frank Wall Street Reform and Consumer Protection Act. The rule requires a registrant to disclose, in...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

White & Case LLP

SEC Adopts Pay Versus Performance Disclosure Rules

White & Case LLP on

On August 25, 2022, the Securities and Exchange Commission (the "SEC") adopted new rules implementing the pay versus performance disclosure mandated by Congress in the Dodd-Frank Wall Street Reform and Consumer Protection Act...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

Wilson Sonsini Goodrich & Rosati

SEC Adopts Final Pay-for-Performance Rules

On August 25, 2022, the U.S. Securities and Exchange Commission (SEC) approved final rules on the correlation between executive pay and company performance (pay-for-performance). As discussed in our previous client alert,...more

Womble Bond Dickinson

SEC Adopts Pay for Performance Rules

Womble Bond Dickinson on

​​​​​​​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

Orrick, Herrington & Sutcliffe LLP

SEC Adopts Final Pay Versus Performance Disclosure Rule

On August 25, 2022, the SEC adopted a final rule implementing a provision of the Dodd-Frank Act of 2010 requiring public companies to provide clear disclosure of the relationship between executive compensation and company...more

Latham & Watkins LLP

SEC Imposes Expansive New “Pay Versus Performance” Disclosure Requirements on Public Companies

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The new rules significantly expand required disclosure of the relationship between executive compensation and performance metrics, effective for the 2023 proxy season. ...more

Keating Muething & Klekamp PLL

Pay for Performance Rules Finally Here—What You Need to Know

At long last, on August 25, 2022, the Securities and Exchange Commission adopted the pay versus performance disclosure requirements directed by the Dodd-Frank Act over twelve years ago. The surprise rulemaking action is...more

WilmerHale

SEC Adopts Long-Anticipated Pay Versus Performance Disclosure Rules

WilmerHale on

On August 25, 2022, the Securities and Exchange Commission (SEC) adopted, by a 3-2 vote, the long-anticipated Pay Versus Performance disclosure rules. After two rounds of public comment (see our prior alert and the reopening...more

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