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SEC Comment Letters: Pay Versus Performance Table Do’s & Don’ts

By Randi Morrison posted 11-06-2023 05:59 PM

  

Bryan Cave’s “Review of recent SEC staff comments on Pay versus Performance Table” illustrates by example numerous Pay Versus Performance Table requirements that companies failed to satisfy in their initial year disclosures. Instructively, the memo pairs excerpts from recent SEC staff comment letters with specific requirements of the rule for ease of review. 

See our recent report: “SEC Comment Letter Analyses: Pay Versus Performance” and additional resources on our Pay for Performance page.

                 This post first appeared in the weekly Society Alert!

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