Last month, the SEC issued an interpretive release addressing Item 303 of Reg S-K (see Rel. No. 33-10751, Key Performance Metrics (2020)). Although this guidance relates to the MD&A, it is, of course, also relevant to executive compensation and disclosure professionals, because key performance metrics are usually an important part of short- and long-term incentive compensation plans and disclosures. The release is relatively benign but worth reviewing for its increased scrutiny on performance metrics. The following is from the latest issue of The Corporate Counsel (subscription required): READ MORE