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Executive Compensation Comment Period

McDermott Will & Emery

SEC hosts roundtable on executive compensation disclosure requirements

McDermott Will & Emery on

On June 26, 2025, the US Securities and Exchange Commission (SEC) hosted a roundtable attended by issuers, institutional investors, third-party advisors, and industry groups to discuss potential updates to current executive...more

Troutman Pepper Locke

Executive Compensation Disclosures Are Back on the (Round)table at the SEC

Troutman Pepper Locke on

The SEC announced on May 16 that it will host a roundtable discussion with representatives from public companies, compensation consultants, lawyers, investors, and other stakeholders on the topic of executive compensation...more

BCLP

Proxy Advisors Kick-Off the Holiday Season: Glass Lewis Releases ’25 Updates; ISS Seeks Feedback on Proposed ’25 Changes

BCLP on

ISS and Glass Lewis generally publish changes to their proxy voting policies around this time of year. Glass Lewis recently issued its 2025 US Policy Guidelines listing changes and clarifications....more

Bradley Arant Boult Cummings LLP

IRS Announces Transition Period for Roth Catch-Up Contributions

The Internal Revenue Service (IRS) has announced a two-year administrative transition period that delays until 2026 the new rule that catch-up contributions made by certain higher‑income participants in 401(k), 403(b), and...more

Nelson Mullins Riley & Scarborough LLP

SEC Reopens Comment Period for Clawback Rules

The SEC again reopened the comment period on July 13, 2022 for its proposal for Listing Standards for Recovery of Erroneously Awarded Compensation, more commonly known as clawback rules. The proposed rules would direct the...more

Mayer Brown Free Writings + Perspectives

SEC Reopens Clawback Comment Period…Again

On June 8, 2022, the US Securities and Exchange Commission (“SEC”) issued a release (“New Reopening Release“), reopening the comment period on the clawback listing standard rules that it proposed in 2015 (“2015 Proposal“). At...more

BakerHostetler

SEC Reopens Comment Period on Dodd-Frank Act Pay-Versus-Performance Rule

BakerHostetler on

The SEC has reopened the comment period for the 2015 Proposal regarding the Dodd-Frank Act pay-versus-performance rule. In conjunction with the reopening, the SEC has proposed several additional disclosure requirements in an...more

Mayer Brown Free Writings + Perspectives

SEC Reopens Pay Versus Performance Comment Period

On January 27, 2022, the US Securities and Exchange Commission (SEC) voted to reopen the comment period on the pay versus performance rule that it proposed in 2015 (2015 Proposal). The proposed rule being contemplated would...more

Mayer Brown Free Writings + Perspectives

The SEC’s Pay-versus-Performance Disclosure Proposal is Back

On January 27, 2022, the US Securities and Exchange Commission (SEC) reopened the comment period for the proposed “pay-versus-performance” rules mandated by the Dodd-Frank Act, which would require disclosure of information...more

Katten Muchin Rosenman LLP

SEC Comment Period Ends for Controversial Proposal Regarding Clawbacks of Executive Incentive Compensation Without Official Action

On October 14, Chairman Gensler announced that the Securities and Exchange Commission (SEC) would reopen the comment period for the controversial compensation clawback rule that it had initially proposed in 2015 in response...more

BCLP

2022 Proxy Season - Quick Hits

BCLP on

Considerations for companies planning for next proxy season should include the following: Risk Factors - ..As discussed in our July 13 post, consider current hot topics, including COVID risks, labor market...more

Stinson - Corporate & Securities Law Blog

SEC Reopens Comments on Compensation Clawbacks

In 2015 the SEC proposed rules to implement Section 954 of the Dodd-Frank which added Section 10D to the Securities Exchange Act of 1934. Section 10D requires the SEC to adopt rules directing the national securities exchanges...more

Herbert Smith Freehills Kramer

New Section 162(m) Proposed Regulations

The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more

WilmerHale

IRS Issues Proposed Regulations Under Code Section 162(m)

WilmerHale on

The 2017 Tax Cuts and Jobs Act (TCJA) significantly amended Internal Revenue Code Section 162(m), which generally disallows the deduction of compensation in excess of $1 million paid by a “publicly held corporation” to a...more

Proskauer - Employee Benefits & Executive...

New Excise Tax For Tax-Exempts Can Ensnare For-Profit Employers: Comment Deadline Fast Approaching

As discussed, the IRS’s initial interpretation of a new excise tax under Section 4960 of the Internal Revenue Code could catch for-profit employers who set up foundations, trusts, PACs, and other tax-exempt entities off...more

Holland & Knight LLP

IRS Notice Provides Guidance for Exempt Organizations on Excise Tax

Holland & Knight LLP on

• The Internal Revenue Service (IRS) released IRS Notice 2019-09 (Notice) offering guidance under Section 4960 of the Internal Revenue Code as added by the Tax Cuts and Jobs Act. • Section 4960 applies to certain...more

Katten Muchin Rosenman LLP

Interim IRS Guidance on New Executive Compensation Requirements for Tax-Exempt Entities Creates New Challenges

Under new Section 4960 ("Section 4960") of the Internal Revenue Code of 1986, as amended ("IRC") that was adopted as part of the Tax Cuts and Jobs Act of 2017 (Tax Act), an excise tax under IRC Section 11 (currently 21...more

Eversheds Sutherland (US) LLP

Treasury and IRS issue interim guidance on executive compensation excise tax under section 4960

On December 31, 2018, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) issued Notice 2019-09 (Notice) providing comprehensive interim guidance under section 4960 of the Internal...more

Stinson - Corporate & Securities Law Blog

ISS Seeks Comment on Updated Policies Including Gender Pay Gap

ISS has made available for public comment certain proposed changes to ISS’ benchmark voting policies for 2018 that could generally become effective for the upcoming proxy season. ...more

Winstead PC

Agencies Propose Incentive Compensation Rules for Financial Institutions

Winstead PC on

The Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the U.S. Securities and Exchange Commission recently proposed new restrictions...more

Dorsey & Whitney LLP

The SEC Proposes Rules to Address Investment Advisor and Broker-Dealer Incentive Based Compensation

Dorsey & Whitney LLP on

The SEC recently released a proposed rule pursuant to Section 956 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) with respect to the implementation of incentive-based compensation arrangements...more

Stinson - Corporate & Securities Law Blog

Nasdaq Golden Leash Proposal

Nasdaq recently extended the comment period for its proposed disclosure requirements on golden leash arrangements. Some may wonder why the proposal is controversial. For an answer, please see the post submitted by in-house...more

Allen Matkins

The Fundamental Distinction Overlooked By The SEC

Allen Matkins on

Yesterday marked the close of the comment period on the SEC’s proposed incentive compensation clawback rules.  You can read my comments here.  The proposed rules are fundamentally flawed because the SEC failed to recognize...more

Ballard Spahr LLP

SEC Proposed Rule 10D-1 Regarding Clawback Policies

Ballard Spahr LLP on

The Securities and Exchange Commission (SEC) recently proposed rules requiring national securities exchanges such as the New York Stock Exchange and NASDAQ to establish listing standards requiring publicly traded companies to...more

Womble Bond Dickinson

SEC Proposes New Clawback Rules

Womble Bond Dickinson on

Last Wednesday, the Securities and Exchange Commission (SEC) proposed new Rule 10D-1 to require public companies to adopt and enforce clawback policies to recoup incentive-based compensation paid to current and former...more

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