The SEC's New Pay Versus Performance Rule: FAQ

By: Ran Ben-Tzur , Amanda L. Rose , Elizabeth A. Gartland , Marshall Mort , Shawn E. Lampron

Public Company Insight:

In August 2022, the SEC adopted rules that require public companies to disclose the relationship between compensation “actually paid” to their executives and their financial performance, as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Pay Versus Performance). These rules will apply to proxy and information statements that include executive compensation disclosure for fiscal years ending on or after December 16, 2022.

Given these changes, partners Ran Ben-Tzur, Amanda Rose, Elizabeth Gartland, Marshall Mort and Shawn Lampron have prepared an FAQ covering which companies are impacted and what they need to know to help properly disclose the relationship between executive “compensation actually paid” and a company’s financial performance.

Download the FAQ here.