News & Analysis as of

Pay-for-Performance Dodd-Frank Wall Street Reform and Consumer Protection Act Proposed Regulation

Wilson Sonsini Goodrich & Rosati

Comment Periods Close Again for Proposed Clawback and Pay-for-Performance Rules: A Refresher

Two Securities and Exchange Commission (SEC) executive compensation rules on recoupment of incentive compensation in the event of a financial restatement (clawbacks) and the correlation between executive pay and company...more

A&O Shearman

New Year, New Rules: Arrival of the Final Hedging Disclosure Rules

A&O Shearman on

On December 18, 2018, the Securities and Exchange Commission (SEC) approved long-awaited final rules implementing Section 955 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Consistent with the proposed...more

Cooley LLP

Blog: What’s Happening With Those SEC Proposals For Dodd-Frank Clawbacks And Disclosure Of Pay For Performance And Hedging?...

Cooley LLP on

The SEC’s latest Regulatory Flexibility Agenda, which identifies those regs that the SEC intends to propose or adopt in the coming year— and those deferred for a later time—has now been posted. The Agenda shifts to the...more

Benesch

SEC Proposes Rules Mandating Executive Compensation “Clawback” Policies

Benesch on

On July 1, 2015, the Securities and Exchange Commission (the SEC) proposed new rules that would mandate U.S. stock exchanges to establish and enforce standards requiring listed companies to adopt compensation recovery...more

Morgan Lewis

SEC Proposes Rules Requiring Companies to Adopt, Disclose, and Comply With Clawback Policies on Erroneously Awarded Executive...

Morgan Lewis on

On July 1, 2015, the US Securities and Exchange Commission (SEC) issued a long-awaited release (Proposing Release) proposing rules that would direct the national securities exchanges to establish listing standards requiring...more

Cooley LLP

Alert: SEC Proposes New Rules on Pay Versus Performance When "Compensation Actually Paid" is Not Compensation Actually Paid and...

Cooley LLP on

On April 29, 2015, the SEC voted to propose rules requiring public companies to disclose the relationship between compensation actually paid and company financial performance. The proposal comes almost five years after the...more

WilmerHale

SEC Proposes Dodd-Frank Pay-Versus-Performance Disclosure Rules

WilmerHale on

Overview - On April 29, 2015, the Securities and Exchange Commission (SEC) voted 3-2 to propose new rules requiring companies to disclose the relationship between executive compensation “actually paid” and the...more

Parker Poe Adams & Bernstein LLP

The New Pay-for-Performance Proposal – A Misstep by the SEC

The SEC last week finally proposed rules mandated by Dodd-Frank providing for disclosure of the relationship between compensation actually paid to executives and company financial performance. While it is important to...more

Katten Muchin Rosenman LLP

SEC Proposes New Pay-for-Performance Rules

On April 29, the Securities and Exchange Commission proposed new rules to require annual disclosure in proxy and information statements under the Securities Exchange Act of 1934 regarding the relationship between executive...more

Cooley LLP

Blog: With Two Dissents, SEC Proposes Pay-For-Performance Disclosure Rules

Cooley LLP on

Wednesday, by a three to two margin, the SEC voted to propose rules requiring companies to disclose executive pay for performance. The proposal comes five years after passage of Dodd-Frank, which imposed the obligation on the...more

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