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 of the comment period), the adoption of these rules implements Section 953(a) of the Dodd-Frank Act, one of the remaining governance and executive compensation-related provisions applicable to public companies under the Dodd-Frank Act.