Login to MyACC
ACC Members

Not a Member?

The Association of Corporate Counsel (ACC) is the world's largest organization serving the professional and business interests of attorneys who practice in the legal departments of corporations, associations, nonprofits and other private-sector organizations around the globe.

Join ACC

On August 25, 2022, the Securities and Exchange Commission (SEC) adopted Release No. 34-95607 implementing a final rule (Final Rules) that requires covered publicly traded companies to provide both tabular and narrative and/or graphical disclosure of the relationship between executive compensation “actually paid” (as defined) by the company to its named executive officers and the company’s performance over a specified time period (Pay Versus Performance Disclosure). The Pay Versus Performance Disclosure requirements apply to all publicly traded companies, except emerging growth companies, foreign private issuers, registered investment companies. As discussed in this article developed by Latham & Watkins, smaller reporting companies (SRCs) are subject to the Final Rules but are permitted to provide scaled disclosure. Check out this article to find out where the Pay Versus Performance Disclosure is required to be included and where its not and any other relevant details including key determinations and actions required.

10 Pages
Not an ACC Member? Request a trial membership.
Region: United States
The information in any resource collected in this virtual library should not be construed as legal advice or legal opinion on specific facts and should not be considered representative of the views of its authors, its sponsors, and/or ACC. These resources are not intended as a definitive statement on the subject addressed. Rather, they are intended to serve as a tool providing practical advice and references for the busy in-house practitioner and other readers.

This site uses cookies to store information on your computer. Some are essential to make our site work properly; others help us improve the user experience.

By using the site, you consent to the placement of these cookies. For more information, read our cookies policy and our privacy policy.