Resource Library Executive & Director Pay Design

The SEC recently released several Compliance & Disclosure Interpretations on the Pay vs. Performance disclosure requirements, which include changing the measurement period for the change in fair value of equity in IPO year to be based on their fair value at the end of the prior fiscal year, not the IPO date.

Faegre Drinker Biddle & Reath LLP provides preparation considerations for companies seeking to implement SEC-compliant clawback policies by the December 1st compliance deadline, which include approving the go-forward policy, requiring cover officers to sign an acknowledgement of the updated policy, reviewing disclosure requirements for policy changes which must be filed in the 10-K, and more.

CompensationStandards.com’s “Executive Compensation Disclosure Treatise” has been updated to include information on Pay vs. Performance disclosure guidelines, interpretations, and analysis.

Equilar Inc.’s study of CEO and CFO perks and benefits at the largest 500 US companies by revenue finds that the value of some perks, such as housing, have outpaced increases in the costs of the underlying goods, while others, such as automobile and aircraft perks, have not.

Equilar Inc.’s recent study on CEO tenure at S&P 500 companies finds that median CEO tenure has decreased 20% from 6.0 years in 2013 to 4.8 years in 2022.

Cooley LLP outlines more details on how to navigate the updated SEC disclosure requirements, including what needs to be filed in the table that outlines daily repurchase data quarterly in 10-Q/ 10-Ks and what situations qualify for the checkbox regarding trading by officers or directors surrounding announcement of repurchase program.