Mercer

SEC updates executive pay disclosure guidance, considers rule changes

New SEC Compliance & Disclosure Interpretations (C&DIs) clarify executive pay disclosures under Regulation S-K -- and contain some surprises. Issues addressed include how to fill out the Summary Compensation Table for NEOs serving fewer than three years, when to report tax gross-ups, whether to disclose life insurance proceeds, and how to calculate and report various equity incentives. In recent remarks, the SEC chair indicates the commission also is considering a variety of changes to expand and revise its executive pay disclosure rules.  (Select News, 5 Jun 2009)


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