SEC Postpones Executive Compensation provisions of Dodd-Frank Act

SEC updates implementation schedule of Dodd-Frank Act

January 5 2012

The SEC recently updated the Upcoming Activity schedule for implementing the Dodd-Frank Act.  The executive compensation provisions of the Act affected are listed below.

How many will be adopted before Election Day?

January – June 2012 (planned)
§951:  Adopt rules regarding disclosure by institutional investment managers of votes on executive compensation
§952:  Adopt exchange listing standards regarding compensation committee independence and factors affecting compensation adviser independence; adopt disclosure rules regarding compensation consultant conflicts
§§953 & 955:  Propose rules regarding disclosure of pay-for-performance, pay ratios, and hedging by employees and directors
§954:  Propose rules regarding recovery of executive compensation

July – December 2012 (planned)
§§953 & 955:  Adopt rules regarding disclosure of pay-for-performance, pay ratios, and hedging by employees and directors
§954:  Adopt rules regarding recovery of executive compensation
§956:  Adopt rules (jointly with others) regarding disclosure of, and prohibitions of certain executive compensation structures and arrangements for financial institutions
§952:  Report to Congress on study and review of the use of compensation consultants and the effects of such use(Yes, a few of the rules appear as “planned” under both periods.)

SEC LINK
Dodd-Frank Implementation Calendar