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SEC Comment Letter Analyses: Pay Versus Performance

By Randi Morrison posted 10-15-2023 06:12 PM

  

Both Barnes & Thornburg and Equity Methods provided helpful analyses of the first tranche of SEC comment letters on the new pay versus performance disclosure. Barnes & Thornburg identifies seven comment themes supported by one click-accessible comment letters, while Equity Methods categorizes the comments into three types of issues—calculation, presentation, and disclosure flaws, with reference to its Disclosure Readiness Checklist.

Access additional resources on our Pay for Performance page.

           This post first appeared in the weekly Society Alert!

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