Preparing for Year Two of Pay versus Performance Disclosures

The SEC’s final Pay versus Performance (PVP) disclosure rules were issued on August 25, 2022. Given the number of implementation issues that were raised as companies struggled to comply with the new rules, the SEC staff issued several Compliance and Disclosure Interpretations (CDIs) to clarify the disclosure requirements: fifteen CDIs were issued on February 10th, nine CDIs were issued on September 27th, and ten CDIs (including revisions to two prior CDIs) were issued on November 21st.

This Viewpoint highlights some of the most important SEC guidance that companies should consider in preparing their 2024 PVP disclosure. READ MORE