The SEC’s New Pay Versus Performance Rule: Guidance for Companies and Investors
Companies and investors now have one year of experience with the SEC’s new pay versus performance (PvP) disclosure rules. Companies put tremendous effort into preparing these new disclosures which require companies to report a new compensation measure – Compensation Actually Paid (AP) – that reflects the year end value of unvested equity grants. Companies reported a three year history of CAP in 2023 but need to report a four year history in 2024 and a five year history in 2025 and later years. To help investors understand how pay is related to performance, companies have to report their own cumulative [...]