SEC Proposes Pay-for-Performance Disclosure Rules

Today, Pillsbury attorneys Mark Jones and Kathleen Bardunias, and summer associate Kevin Lin, published their client alert SEC Proposes Pay-for-Performance Disclosure Rules. The Advisory discusses the SEC’s recently proposed rule under the Dodd-Frank Wall Street Reform and Consumer Protection Act that would require public companies to disclose the relationship between the compensation actually paid to certain key executives and the financial performance of the company, as measured by total shareholder return. If the proposed rule is finalized during 2015, affected companies may be required to make the “pay-for-performance” disclosures as early as the 2016 proxy season.