Jenner & Block

Client Alert: SEC Balances Comparability Against Flexibility in Proposed Pay-Versus-Performance Rule

On April 29, 2015, the Securities and Exchange Commission (the SEC) voted 3 to 2 to issue a long-awaited proposed rule on pay-versus-performance disclosure mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). The proposed rule seeks to provide investors with standardized information that can be compared across companies while preserving companies’ flexibility to tell their own stories regarding the relationship between executive compensation and company performance. The comment period will be open for 60 days.