SEC Proposes New Pay Versus Performance Disclosure Rules

On April 29, 2015, the United States Securities and Exchange Commission (SEC) voted three-to-two to propose new rules that would prescribe new mandatory Pay versus Performance disclosure. The new disclosure would include specific information showing the relationship between executive compensation "actually paid" and financial performance of the registrant. Public companies (other than emerging growth companies, foreign private issuers and registered investment companies) would be covered by the proposed rules.

Covered issuers would not be allowed to use their existing pay for performance disclosure approaches to meet the requirements under the proposed rules. Instead, covered issuers would be required to include specific types of pay and performance information using the following new table: