Partners Shalom Huber, Joseph Penko and Erica Schohn and associate Loren Koles look at eight new and two revised Compliance & Disclosure Interpretations (C&DIs) from the SEC relating to the final pay-versus-performance (PVP) disclosure rules adopted last year. The most recent C&DIs:
- Supplement the C&DIs issued by the staff in February and September 2023;
- Provide additional answers to questions that companies encountered in complying with the disclosure rules for the first time during the 2023 proxy season; and
- Clarify the portions of the earlier C&DIs subject to the most debate.