SEC Sets Up Special Public Comment Process for Dodd-Frank Act
The SEC seems to understand that there might be many people that want to provide comments on the Dodd-Frank Act before the SEC has had time to pull together draft rules. Yesterday, the SEC has launched a new public comment page for those interested in commenting on Dodd-Frank to provide comments prior to the issuance [...]
Another Week, Another Set of SEC Guidance
On Friday, March 12, 2010, the SEC Staff again updated the Regulation S-K Compliance & Disclosure Interpretations (C&DIs). Here is a quick summary of the three new bits of clarification that the SEC Staff offers for the revised proxy disclosure rules: Q. 119.25-NEIP award based on performance during 2010 granted in January 2010. After the [...]
New SEC Staff Guidance Addresses Equity Awards’ Disclosure
On March 1, 2010, the SEC Staff again updated the Regulation S-K Compliance & Disclosure Interpretations (C&DIs). If a company chooses to report the grant date fair value assumptions for equity awards in relation to the Grants of Plan-Based Awards Table, it can satisfy the Summary Compensation Table disclosure requirements for such information by referencing [...]
More SEC Guidance on Revised Proxy Disclosure Rules
On February 16, 2010, the SEC Staff updated the C&DIs for Regulation S-K with a few additional questions and answers, as follows: Question 116.07 Question: Instruction 3 to Item 401(a) provides that if the information called for by paragraph (a) is being presented in a proxy or information statement, no information need be given respecting [...]
RMG Issues FAQs on New SEC Proxy Disclosure Rules
RiskMetrics Group (RMG) recently issued several FAQs related to the new SEC proxy disclosure rules. Previously, I blogged about the RMG FAQ regarding Compensation Risk Disclosures, and today I will address the two other FAQs, one on compensation consultant conflicts and the other on the enhanced disclosure about directors – qualifications, diversity policies, and board [...]


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