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SEC Issues New “Pay Versus Performance” Guidance

The SEC provides much-needed guidance on the new pay versus performance disclosure requirements that will be applicable to the current proxy season. On February 10, 2023, the Staff of the Securities and Exchange Commission...more

How to Navigate the SEC’s New Clawback Rules

The rules direct stock exchanges to require issuers that are publicly listed in the US to adopt clawback policies for the mandatory recovery of erroneously awarded incentive compensation... ...more

New SEC Staff Guidance on CEO Pay Ratio Disclosure Rules – Determining the Median Employee

Guidance clarifies how to determine the employee population and median employee for the ratio, though questions remain. The staff of the Division of Corporation Finance of the Securities and Exchange Commission (SEC) has...more

SEC Adopts CEO Pay Ratio Disclosure Rules

The SEC has adopted rules requiring companies to disclose the pay ratio between their CEO and median compensated employee. Last week, the Securities and Exchange Commission (the SEC) adopted final rules requiring...more

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