On September 27, 2023, the staff of the Securities and Exchange Commission’s (SEC’s) Division of Corporation Finance issued 10 new Compliance & Disclosure Interpretations (C&DIs) relating to the pay-versus-performance (PVP) disclosure rules adopted last year. This new set of C&DIs supplements the 15 C&DIs regarding the PVP disclosure rules issued by the staff on February 10, 2023, and provides answers to some of the questions that companies encountered in complying with the PVP disclosure rules for the first time during the 2023 proxy season. READ MORE