SEC moving towards adopting “pay vs. performance” rules
February 4, 2022 •
It’s been a dozen years since the Dodd-Frank Act mandated that the SEC adopt rules regarding pay vs. performance. And even though the SEC proposed such rules in 2015, nothing was ever adopted. Now the SEC seems to be moving towards adopting final rules by re-opening the comment period. Here is a summary of the questions – from this blog by Cooley’s Cydney Posner – that the SEC asks in this new “request for comment” that gives an indication of where the SEC is headed in terms of what a final rule might look like…