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...