SEC’s New Pay Versus Performance Disclosure Rule

On September 6, 2022, Cravath distributed a memo for its clients and other stakeholders entitled “SEC’s New Pay Versus Performance Disclosure Rule: Important Things To Know,” which summarizes the background and key features of the SEC’s recently adopted rule to implement the “pay versus performance” disclosure requirements of the Dodd‑Frank Wall Street Reform and Consumer Protection Act of 2010. The memo describes the background and substance of the rule, including newly required compensation calculations, and recommends companies begin working with advisors promptly to prepare for this disclosure.

Please click here to read the memo.

On October 28, 2022, the memo was published by the Harvard Law School Forum on Corporate Governance. Please click here for the related news item.