Based on its analysis of 160 S&P 500 Pay Versus Performance disclosures, this memo from Pay Governance: “What Shareholders Can Learn from the SEC's New Pay Versus Performance Disclosure” discusses the relationships between: (i) Compensation Actually Paid and Summary Compensation Table dollar values and (ii) CAP and TSR (Total Shareholder Return), and the key drivers in year-over-year changes in CAP dollar values. The memo suggests questions companies should consider to be responsive to investor engagement on this topic as the new disclosure requirement matures.