On September 21, the Division of Corporation Finance of the Securities and Exchange Commission issued a new Compliance and Disclosure Interpretation (C&DI) regarding the treatment of benefits provided to executive officers in light of the COVID-19 pandemic and whether such benefits constitute perquisites or personal benefits that must be disclosed in a registrant’s summary compensation table and included when determining the registrant’s three most highly compensated officers (other than the registrant’s principal executive officer and principal financial officer) for identifying the “named executive officers.”
Continue Reading SEC Issues C&DI on COVID-19 Related Benefits
executive compensation
SEC Division of Corporation Finance Issues Five Additional C&DIs Relating to Pay Ratio Disclosure Rule
By Mark D. Wood, Mark J. Reyes & Agnes I. Park on
Posted in SEC/Corporate
On October 18, the Securities and Exchange Commission’s Division of Corporation Finance (Division) issued five new Compliance and Disclosure Interpretations (C&DIs) with respect to Item 402(u) of Regulation S-K, the rule that requires a registrant to disclose the ratio of its principal executive officer’s total annual compensation to the total annual compensation of their median employee (the “Pay Ratio Disclosure Rule”).
Continue Reading SEC Division of Corporation Finance Issues Five Additional C&DIs Relating to Pay Ratio Disclosure Rule
Financial Regulatory Agencies to Issue New Proposed Compensation Rules
By Jeffrey M. Werthan on
Posted in Banking, Dodd-Frank Developments
On April 21, the National Credit Union Administration issued proposed prototype regulations with other financial institution regulatory agencies (Agencies) to likely follow suit. Required under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Act), the rule is intended to (1) prohibit incentive-based payment arrangements that the Agencies determine encourage inappropriate risks by certain financial institutions by providing excessive compensation or that could lead to material financial loss; and (2) require those financial institutions to disclose information concerning incentive-based compensation arrangements to the appropriate federal regulator.
Continue Reading Financial Regulatory Agencies to Issue New Proposed Compensation Rules