The New SEC Pay-for-Performance Rules Require A Thoughtful Approach

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Section 953(a) of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 directs the SEC to adopt rules requiring public companies to provide disclosure of executive pay as compared to company performance. The SEC did not propose rules in response to this mandate until 2015, and for a time thereafter the proposal disappeared from the SEC’s agenda. In January 2022, the SEC reopened the comment period and updated its proposal. With some additional changes, the new pay-for-performance rules were adopted on August 25, 2022.

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