Twelve Years Later: Final SEC Disclosure Rules Add Significant Complexity and Cost for Companies
The Securities Exchange Commission (“SEC”) recently issued long-awaited final rules on Pay Versus Performance (“PvP”) disclosure and clawbacks. These were mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) that was passed in 2010 in response to the financial crisis. The SEC originally proposed the rules in 2015 and re-opened the comment period most recently in early 2022. The final rules add significant complexity to existing proxy disclosure requirements and may pose a substantial administrative burden on companies.
Key Takeaways:
1. Overview of the rules and how it may impact your company
2. Insights into early disclosure
3. Discussion around unanswered questions