SEC Adopts Pay Versus Performance Disclosure Rules

As required by the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act (the "DoddFrank Act"), the Securities and Exchange Commission (the "SEC") has adopted final rules requiring most public companies to present executive pay versus performance ("PVP") disclosures, which are intended to help investors more clearly understand the relationship between executive compensation and company financial performance in prior years, and make such information readily comparable across public companies.

Affected companies (excluding emerging growth companies, registered investment companies, and foreign private issuers) are required to include significant new executive compensationrelated disclosures in their proxy statements and information statements, beginning with 2023 proxy statements and information statements for companies with fiscal years ending on or after December 16, 2022.