SEC updates implementation schedule of Dodd-Frank Act
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.)