Dodd-Frank.com

ISS Announces Pay-for-Performance Methodology Updates for 2017

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ISS announced changes to the methodology underlying its pay-for-performance models for companies in the U.S. and other markets to take effect Feb. 1, 2017. ISS will present relative evaluations of return on equity, return on assets, return on invested capital, revenue growth, EBITDA growth, and cash flow (from operations) growth... Read More

Topics: Employment, Executive Compensation, Public Companies and Securities

SEC Exams Looking for Whistleblower Violations

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SEC staff in the Office of Compliance Inspections and Examinations are examining compliance with key whistleblower provisions arising out of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The staff is examining registered investment advisers and registered broker-dealers, reviewing, among other things, compliance manuals, codes of ethics, employment agreements,... Read More

Topics: Broker-Dealer, Employment, Executive Compensation, Investment Advisers, Litigation

New Proposed Rules on Banker Incentive Compensation Released

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The National Credit Union Administration, or NCUA, became the first of six Agencies to unveil a revised rule proposal under Section 956 of the Dodd-Frank Act: prohibiting incentive-based payment arrangements that the Agencies determine encourage inappropriate risks by certain financial institutions by providing excessive compensation or that could lead to... Read More

Topics: Banking, Broker-Dealer, Employment, Executive Compensation

Does the Dodd-Frank Compensation Clawback Make Sense?

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Jesse M. Fried, Cambridge, Massachusetts, recently published a paper on the required Dodd-Frank compensation clawback.  In Mr. Fried’s view, the SEC’s proposed Dodd-Frank clawback, while reducing executives’ incentives to misreport, is overbroad. According to Mr. Fried, the economy and investors would be better served by a more narrowly targeted “smart”... Read More

Topics: Employment, Executive Compensation, Public Companies and Securities

Internal Pay Equity Disclosures: Ratio of CEO Pay to Other NEOs

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Many are aware of the Dodd-Frank requirement to disclose the ratio of the median employee’s annual total compensation to the total annual compensation of the principal executive officer. We have published some examples of early adopters. Others have taken the internal pay equity issue further and disclosed ratios related to... Read More

Topics: Employment, Executive Compensation, Public Companies and Securities