SEC Proposes Pay Versus Performance Disclosure Rules

On Wednesday, April 29, 2015, the SEC proposed rules on the disclosure of executive pay versus company performance. The proposed rules implement Section 953(a) of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which directs the SEC to adopt rules requiring public companies to disclose the relationship between executive compensation actually paid and the financial performance of the company.

New Tabular Disclosure

The proposed rules would add a new Item 402(v) to Regulation S-K, which would require in proxy and information statements in which executive compensation disclosure is required, a new "Pay Versus Performance" table that sets forth the following information for each of the last five fiscal years: