The Securities and Exchange Commission (SEC) announced that it will host a roundtable meeting on June 26, 2025, to discuss potential updates to the executive compensation disclosure requirements. This meeting is open to the public, who are invited to share comments and questions before or after the event. It provides stakeholders an opportunity to influence future changes in the executive compensation disclosure regime.
Since its introduction in a form similar to its current structure in 1992, the executive compensation disclosure regime has grown more complex. A major overhaul occurred in 2006, with further expansions following the mandates of the 2010 Dodd-Frank Act. The upcoming roundtable may serve as a critical opportunity for input on these matters, though it is likely just an initial step in what could be an extensive review process.
SEC Chairman Paul Atkins stated that while disclosures have become more complex and lengthy, it remains unclear if they offer investors additional material information for investment and voting decisions. He raised several questions for SEC staff consideration, including what aspects of current rules work well or poorly, burdens imposed by these rules, lessons from say-on-pay and clawback disclosures, and challenges related to specific disclosures like perquisite rules for executive security expenses.
Public comments can address these issues or introduce new ones relevant to individual interests. Cooley encourages those interested in submitting comments independently or through their firm contacts but warns that submissions will be posted unchanged online. Comments should avoid sensitive or confidential information.
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