As we recently reported in our December 18, 2009 blog article, the SEC adopted substantial amendments on December 16, 2009 that significantly expand the executive compensation and corporate governance disclosure requirements for publicly held companies. These new rules were presumably adopted now in order to become effective for the 2010 proxy season but, as we noted in our blog, the SEC's adopting release did not provide much guidance regarding the effective dates of the new rules.

Fortunately, on December 22, 2009, the SEC issued five new compliance and disclosure interpretations ("Proxy Disclosure Enhancements Transition") in Q&A format that provide clarifications regarding when the new rules are operative.