학술논문

SEC proposes “pay-for-performance” disclosure rule
Document Type
JOURNAL
Source
Journal of Investment Compliance, 2015, Vol. 16, Issue 3, pp. 24-27.
Subject
Dodd-Frank Act
Pay for performance
Securities and Exchange Commission (SEC)
Actual compensation
Total shareholder return (TSR)
Language
English
ISSN
1528-5812
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.