Trick Or Treat? Changes To Canadian Executive Compensation Disclosure Rules Come Into Effect October 31, 2011

The Canadian Securities Administrators (CSA) has tightened its executive compensation disclosure requirements and is requiring additional disclosure regarding the qualifications of the compensation committee, the consideration of risks associated with the company's compensation practices and fees paid to compensation consultants. Canadian banks will be among the first to contend with the new changes as the amendments apply to companies with a fiscal year ending on or after October 31, 2011.

The final amendments are generally consistent with the changes proposed by the CSA in November, 2010 and reflect not only some of the rules adopted by the U.S. Securities and Exchange Commission in response to the Dodd-Frank Wall Street Reform and Consumer Protection Act, but also concerns raised over the last two years respecting compliance with the spirit and intent of the Canadian executive compensation disclosure rules. The specific changes from existing Canadian executive