ARTICLE
9 April 2025

Pay vs. Performance And Cybersecurity Disclosure Rules: Will The SEC Retract Rulemaking?

KM
Keating, Meuthing & Klekamp

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Keating Muething & Klekamp PLL is a nationally recognized law firm of approximately 130 lawyers in Cincinnati, Ohio. We deliver sophisticated legal solutions to individuals and businesses of all sizes — from start-up companies to Fortune 50 corporations. While the firm has primarily built its reputation in the tri-state area, including Ohio, Kentucky, and Indiana, our unwavering client-first approach has helped us establish a national and international presence.

Since 1954, KMK Law has been a pillar of the Cincinnati community. The attorneys and staff at KMK Law have dedicated themselves to serving as trusted advisors for private and public companies, nonprofits, charity-focused organizations, and individuals from every walk of life. Whether our counsel is to a multi-billion dollar company, or an individual working to make sure their life’s work is protected for their family and the organizations they support, we are proud and honored to help those clients achieve their aspirations, every time.

On March 31, 2025, members of the U.S. House of Representatives Committee on Financial Services sent a letter to Mark Uyeda, Acting Chairman of the U.S. Securities and Exchange Commission.
United States Corporate/Commercial Law

On March 31, 2025, members of the U.S. House of Representatives Committee on Financial Services sent a letter to Mark Uyeda, Acting Chairman of the U.S. Securities and Exchange Commission. Seeking to "undo the damage from former Chairman Gary Gensler's tenure," the letter requests that the SEC withdraw fourteen final and proposed rules, including both the SEC's Pay Versus Performance rules (adopted August 2022) and rules related to Cybersecurity Risk Management, Strategy, Governance and Incident Disclosure (adopted July 2023). The SEC may withdraw adopted rules pursuant to the Administrative Procedure Act, which generally involves a public notice and comment period. It will be interesting to see the response of incoming SEC Chairman Paul Atkins. Stay tuned.

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