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Legal Update

US Securities and Exchange Commission Proposes Pay Versus Performance Disclosure Rule

13 May 2015
Mayer Brown Legal Update
The US Securities and Exchange Commission has proposed a “pay versus performance” rule to require SEC reporting companies to disclose in a clear manner the relationship between executive compensation actually paid and the financial performance of the company. The rule would require disclosure in proxy or information statements in which executive compensation information is required to be included pursuant to Item 402 of Regulation S-K. Comments on the proposed rule must be submitted by July 6, 2015.


  • Laura D. Richman
    T +1 312 701 7304
  • Michael L. Hermsen
    T +1 312 701 7960
  • Ryan J. Liebl
    T +1 312 701 8392
  • Robert E. Curley
    Senior Counsel, Independent Contractor
    T +1 312 701 7306

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