The SEC has revisited its pay-versus-performance disclosure rule with a fresh batch of question-and-answer guidance about various technical aspects of the one-year old rule.
The guidance, in the form of nine compliance and disclosure interpretations (CD&Is), generally addresses how companies should treat valuation issues and metrics for the purposes of calculating figures in the disclosure and the impact of various vesting terms…
…Last week’s CD&Is arrived on the heels of a series of comment letters SEC sent to companies regarding the substance of their PvP disclosures, CAP calculations or descriptions of the link between pay and performance. According to MyLogIQ, the SEC sent comment letters to 18 companies in recent months including Berkshire Hathaway, Harvard Biosciences, Healthcare Services Group, Tootsie Roll Company, T. Rowe Price Group, and Xylem.
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