Center On Executive Compensation
Advocacy

Center Comments to SEC: Reopening of Comment Period for Pay Versus Performance

Published on: March 4, 2022

Authors: Timothy J. Bartl

Topics: Executive Pay Legislation and Regulation

Dear Ms. Countryman:

The Center On Executive Compensation (“Center”) is pleased to provide comments to the Securities and Exchange Commission (“Commission”) in response to the reopening of the comment period (“Release”) for the 2015 proposal regarding pay versus performance disclosures mandated by Section 953(a) of the Dodd-Frank Act (“2015 Proposal”). The Center remains concerned about several aspects of the 2015 Proposal, along with potential additional requirements discussed as part of the Release. The Center is providing these comments to reiterate and expound upon our views on the 2015 Proposal and to provide the perspective of our membership on the topics and questions raised in the Release...

Read full comment letter here.

MORE PUBLICATIONS

Center Comments to SEC on Proxy Rules for Proxy Voting Advice
Executive Pay Legislation and Regulation

Center Comments to SEC on Proxy Rules for Proxy Voting Advice

December 23, 2021 | Publication
Center Comments to SEC: 2021 Re-Proposal Dodd-Frank Clawback Rule
Executive Pay Legislation and Regulation

Center Comments to SEC: 2021 Re-Proposal Dodd-Frank Clawback Rule

November 17, 2021 | Publication
Quick Survey Results: Impact of Tax Reform
Executive Pay Legislation and Regulation

Quick Survey Results: Impact of Tax Reform

July 27, 2018 | Publication