SEC Reopens Comment Period on 2015 Pay Versus Performance ProposalThis memorandum summarizes the Reopening Release and the changes made to the Proposed Rules and highlights some of the additional questions raised for comment.
Pay for Performance Disclosures Declined by Nearly 50% Since 2017Preparing for the SEC’s Pay Versus Disclosure Rules Equilar
NYSE and Nasdaq Propose Listing Standards Requiring Issuers to Adopt Clawback PoliciesThe NYSE and Nasdaq recently proposed new standards that would require companies to recover erroneously awarded incentive-based compensation consistent with the SEC’s recently adopted clawback policy. Davies Ward Phillips & Vineberg LLP
ESG Disclosures in Proxy StatementsIt is no secret that the U.S. Securities and Exchange Commission (SEC) has recently ramped up its focus on environmental, social and governance (ESG) disclosures. Sidley Austin LLP
Gender Pay GapHas talk delivered in terms of on-the-ground outcomes for women in the workforce? The results are mixed at best. Harvard Law School Forum on Corporate Governance
Tracking PvP Disclosures: The Latest UpdatesPeruse Equilar’s Pay vs. Performance disclosure tracker for examples of unique early Pay vs. Performance disclosures. Equilar
2021 United States Compensation 2021 Proxy Season ReviewThe median CEO pay package was at an all-time high in both the S&P 500 and the Russell 3000 indices, despite the fact that many companies froze or reduced base salaries in response to the pandemic. Institutional Shareholder Services, Inc.
SEC Proposes Rules to Enhance and Standardize Climate-Related Disclosures for InvestorsThe required information about climate-related risks also would include disclosure of a registrant’s greenhouse gas emissions. U.S. Securities|Exchange Commission
Mild reprieve on timing of clawback policyPay increases for CEOs of large-cap companies grew 3.1% in 2023 to $14.3MM at median vs. 13.2% in 2022, likely driven by an increase in equity compensation. Cooley LLP
2022 Proxy and Annual Report SeasonOnce again, it is time to prepare for the proxy and annual report season. Harvard Law School Forum on Corporate Governance