An Early Look at SEC Comment Letters on Pay Versus Performance Disclosures
Authors
Last year, the Securities and Exchange Commission (SEC) adopted new rules that implemented the pay versus performance (PVP) disclosure mandated by Congress in the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The new rules require U.S. registrants to disclose the relationship between executive compensation and the financial performance of the registrant in their proxy and information statements. In general, the rules created new Item 402(v) of Regulation S-K, which requires registrants to:
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