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What to Consider When Strategically Implementing the SEC’s New Pay for Performance Rule

While a time-consuming exercise of limited use to investors, the rule will push issuers to provide clarifying compensation disclosure in the annual proxy. Due to its reliance on accounting values and emphasis on unvested...more

Maximizing Human Capital Disclosure Under New Guidance

A new SEC rule requires, to the extent material to a company’s business as a whole, expanded human capital disclosures, but its disclosure requirements are very general and give companies the ability to “tell their own story”...more

The State of Play on Clawbacks and Forfeitures Based on Misconduct

On July 1, 2015, the SEC issued proposed rules implementing Section 954 of the Dodd-Frank Act, which would obligate national securities exchanges to adopt listing standards that require listed companies to adopt and disclose...more

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