SEC Issues Proposed Rule Requiring Pay Versus Performance Disclosure

On April 29, 2015, the Securities and Exchange Commission (the "SEC" or "Commission") voted 3-2 to propose a rule requiring certain reporting companies to include a new pay-versus-performance disclosure in any proxy or information statement for which disclosure under Item 402 of Regulation S-K is required.¹ The full text of the proposed rule, along with the SEC's specific requests for comment, may be found here. This new disclosure is intended to highlight the relationship between the executive compensation a registrant pays to certain of its executive officers and the financial performance of the registrant, and would apply to public companies (other than foreign private issuers, emerging growth companies or registered investment companies).