SEC Reopens Comment Period for Proposed Pay Versus Performance Rule

On February 3, 2022, Cravath prepared a memo for its clients entitled “SEC Reopens Comment Period for Proposed Pay Versus Performance Rule.” The rule in question was mandated by the Dodd‑Frank Wall Street and Consumer Protection Act of 2010 and was first proposed by the SEC in 2015 and the latest version includes suggestions on broadening the required disclosure that was included in the original proposal. The memo concludes that the required disclosure may result in increased attention from investors and proxy advisory firms on how companies structure their incentive compensation and recommends companies consider informing their boards and/or compensation committees on the SEC’s renewed focus on these rules.

Please click here to read the memo.