Critical SEC Updates for Pay vs. Performance Year Two
By now, most companies have been through their first year PvP disclosure and are revving up for year two. Now is the time to consider the implications of the SEC’s September 27 release of far-reaching C&DIs and adjust calculation and disclosure strategies accordingly. The SEC’s comment letters on PvP disclosures show that the commission is taking disclosure quality and accuracy seriously, which makes these C&DIs an extremely important component of the year-two game plan.
Join us as we walk through the C&DIs and the various situations they’ll impact. We’ll also review the SEC’s comment letters and what these tell us about how the SEC is approaching PvP compliance. More specifically, we’ll explore:
- Clarifications on how performance metrics should be treated in the PvP calculations
- New (and surprising) treatment of retirement eligible awards and how disclosures will need to be adjusted
- A framework for approaching option valuation and how to balance simplicity with GAAP compliance
- Disclosure of performance expectations and valuation assumptions, especially in light of competitive harm concerns
- The SEC’s emphasis on disclosure quality, from major issues of footnote content to minor issues of labeling clarity
- Common themes and “gotchas” from the comment letters published to date and their implications for your own year two disclosure
- Best practices and tips for approaching year two PvP compliance pragmatically and accurately
Join this important webcast to get a jump on your year-two processes.
CPE Credits: 1.0 (available to live webcast attendees)
Field of Study: Accounting
Program Level: Overview
Additional CPE details