Under rules adopted by the Securities and Exchange Commission (“SEC”) implementing the provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act, most public companies have been required to provide two new shareholder advisory votes in their proxy materials this season. These advisory votes – to approve the compensation of the company’s named executive officers, also known as “say-on-pay,” and to approve the frequency of future say-on-pay votes – have presented shareholders and proxy advisory firms with the opportunity to voice their opinions on executive compensation.

We have tracked the approximately 1,600 companies that have included say-on-pay proposals through mid-May 2011 and this client alert highlights certain trends and lessons learned from the results reported on these votes.