News & Analysis as of

Total Shareholder Return (TSR) Pay-for-Performance CD&A

Cooley LLP

What have studies shown so far about PvP disclosure?

Cooley LLP on

In August last year—12 years after the Dodd-Frank mandate— the SEC finally adopted a new rule that requires disclosure of information reflecting the relationship between executive compensation actually paid by a company and...more

Bass, Berry & Sims PLC

Key Considerations for Developing New SEC Pay versus Performance Disclosure

Bass, Berry & Sims PLC on

As proxy preparation season approaches, the SEC’s new pay versus performance (PVP) disclosure rules will present new and unique challenges for many public companies...more

Paul Hastings LLP

Long-awaited Pay v. Performance Rules Adopted

Paul Hastings LLP on

Recently, the U.S. Securities and Exchange Commission (the “Commission”) adopted long anticipated final rules requiring registrants to disclose information regarding the relationship between the actual compensation paid to...more

Mintz - Securities & Capital Markets...

SEC Adopts Pay Versus Performance Compensation Disclosure Requirements

On August 25, 2022, the Securities and Exchange Commission (“SEC”) adopted rules that amend Item 402 of Regulation S-K to require reporting companies to disclose information detailing the relationship between a company’s...more

Vinson & Elkins LLP

SEC Adopts Final “Pay Versus Performance” Rules

Vinson & Elkins LLP on

On August 25, 2022, the Securities and Exchange Commission (the “SEC”) announced that it adopted a final rule requiring companies to disclose information that is intended to reflect the relationship between compensation paid...more

Husch Blackwell LLP

The SEC's Long-Delayed Dodd-Frank Pay-Versus-Performance Disclosure Requirements Have Finally Arrived

Husch Blackwell LLP on

On August 25, 2022, the Securities and Exchange Commission (SEC) adopted the pay-versus-performance disclosure requirements that had been in the works for years. The SEC originally proposed pay versus performance rules...more

Dechert LLP

A Repeat Performance – U.S. SEC Taking Another Look At Executive Pay Versus Performance

Dechert LLP on

The Securities and Exchange Commission (SEC) on January 28, 2022, reopened the comment period with respect to its pending “pay versus performance” proposal (Proposed Rule), which would generally require public companies to...more

Cooley LLP

Blog: More Than Half Of Poll Respondents Plan To Disclose “More Than The Minimum” Under Pay-Versus-Performance Rules

Cooley LLP on

A poll conducted by compensation consultant Towers Watson in the course of its webcast on the SEC’s proposed pay-versus-performance disclosure rules revealed that, if the rules are adopted, more than half of the respondents...more

Orrick, Herrington & Sutcliffe LLP

Pay For Performance Table and Best Proxy Disclosure

The SEC recently released its proposed "pay for performance" rules under one of the last remaining executive compensation requirements mandated by the Dodd-Frank Act. This new "pay for performance" rule requires companies1 to...more

Stinson - Corporate & Securities Law Blog

Observations on the SEC’s Proposed Pay Versus Performance Rule

The SEC has issued a proposed rule to require companies to disclose the relationship between executive compensation and the financial performance of a company. The details of the proposed rule have been well publicized, and...more

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