As we head into March and the start of proxy season, the SEC’s newly required Pay Versus Performance disclosures are front of mind for many that deal with compensation and corporate governance. The Commission just recently released some *timely* clarifications on their rules, called Compliance & Disclosure Interpretations ( SEC’s C&DI’s ), which introduced clarifications (or complexities) for many public issuers just days before some proxy statements went live. Given SEC Chair Gary Gensler’s comments that the new rules “will help investors receive the consistent, comparable, and decision-useful information they need to evaluate executive compensation policies,” we thought an analysis of early disclosure examples might help inform investor utility?
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