Lawyers
Executive compensation partner Jean McLoughlin and corporate partner Kyle Seifried discuss the SEC’s new pay-versus-performance rule changes requiring public companies to disclose how executive compensation tracks with certain SEC required performance criteria in Corporate Secretary. In the article, published on October 25, Jean and Kyle note how the sweeping, prescriptive nature of the new rules creates substantial challenges when it comes to the accurate determination of compensation actually paid and how the new disclosure format may potentially confuse investors and cloud the evaluation of say-on-pay votes.
The SEC’s rapid rollout of the rule changes signals its desire to complete the remaining Dodd-Frank rulemakings and “be more prescriptive in its requirements than in the recent past,” the authors note. “Rather than deferring to corporate filers on how to make executive compensation decisions more transparent, the new rules show a preference for a rules-based regime.”
