Pay v. Performance Archives

Additional 2023 SEC Guidance on Pay Versus Performance Disclosure

January 18, 2024 By Tom Asmar 13 Mins Read

On September 27, 2023 and November 21, 2023, the Securities and Exchange Commission (SEC) issued additional Compliance & Disclosure Interpretations (CDIs) clarifying certain technical aspects of the pay versus performance (PVP) disclosure rules under Item 402(v) of Regulation S-K[1]. These CDIs are intended to supplement the CDIs covering PVP disclosure that were issued by the SEC on February 10, 2023.[2] By way of background, covered public companies must comply with the PVP disclosure rules beginning…

SEC Issues Guidance on Pay Versus Performance Disclosure Rules

March 6, 2023 By Tom Asmar 7 Mins Read

On February 10, 2023, the Securities and Exchange Commission (SEC) issued Compliance & Disclosure Interpretations (CDIs) regarding the pay versus performance (PVP) disclosure rules under Item 402(v) of Regulation S-K[1]. The PVP disclosure rules apply to covered companies beginning with proxy statements or information statements filed for fiscal years ending on or after December 16, 2022 and generally require disclosure of (i) a PVP table accompanied by a narrative and/or graphical explanation of the relationship…

New Pay Versus Performance Disclosure Rule Effective for 2023 Proxy Season

September 8, 2022 By Sinead Kelly, Victor Flores, Tom Asmar, M'Alyssa Mecenas and Jennifer Brevelle 1 Min Read

It’s been 12 years in the making, but the SEC has finally released rules to implement the “pay versus performance” disclosure required by Section 953(a) of the Dodd-Frank Act. The new disclosure of the relationship between executive compensation “actually paid” and financial performance is required to be included in proxy statements or information statements for fiscal years ending on or after December 16, 2022 and is therefore effective for the upcoming 2023 proxy season. For a…