ARTICLE
7 February 2022

New Comment Deadline Set On SEC Executive Compensation Proposal

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The SEC published in the Federal Register a reopening of the comment period on a proposal to amend the executive compensation disclosure rule.
United States Corporate/Commercial Law

The SEC published in the Federal Register a reopening of the comment period on a proposal to amend the executive compensation disclosure rule ("Item 402 of Regulation S-K"). The new deadline for comments is March 4, 2022.

The proposed revisions (initially published in April 2015) implement Exchange Act Section 14(i) ("Proxies - disclosure of pay versus performance"), which was created by Dodd-Frank Section 953. As previously covered, the proposed rule would require that companies disclose the relationship between their executive compensation and financial performance.

The SEC stated that the new comment period accounts for developments in executive pay since the proposal was first published.

Primary Sources

  1. Federal Register: Reopening of Comment Period for Pay versus Performance

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