SEC proposes “pay-for-performance” disclosure rule

Abstract

Purpose

To outline and summarize the new disclosure requirements under the Securities and Exchange Commission’s proposed pay-for-performance rule, as mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Design/methodology/approach

This article highlights the proposed new disclosure requirements, while briefly discussing the technical requirements under the rule. The article concludes with a summary of the next steps in the rulemaking process followed by our observations of various issues raised by the proposed new disclosure requirement.

Findings

While the contours of any new disclosure requirements will depend on the specifics of the final rule, the pay-for-performance rule, as proposed, would represent a significant new annual disclosure obligation for many public companies.

Originality/value

Practical guidance from experienced securities and capital markets attorneys.

Citation

Engvall, D.H., Hooper, R.S., Gumbs, K.D. and Martin, D.B.H. (2015), "SEC proposes “pay-for-performance” disclosure rule", Journal of Investment Compliance, Vol. 16 No. 3, pp. 24-27. https://doi.org/10.1108/JOIC-06-2015-0034