Say-on-Pay Issues — What to Expect this Month from the SEC


The SEC has announced that it expects to issue proposed rules on say-on-pay during October 2010.  This rulemaking is important for public companies because Dodd-Frank mandates that all proxy statements for the first annual shareholders meeting held after January 21, 2011 include a say-on-pay proposal. The SEC has been soliciting... Read More

Topics: Executive Compensation, Public Companies and Securities, Uncategorized

Examples of Dodd-Frank Disclosures in SEC Filings


Dodd-Frank disclosures have begun to proliferate in SEC filings.  We reviewed many recent filings and disclosures fall into the following general categories:  internal controls, forward looking statements,  executive compensation, regulatory matters and risk factors.  Examples are set forth below. Internal Controls PDC 2004-D Limited Partnership  (Filed September 30, 2010) Internal... Read More

Topics: Public Companies and Securities

More Clues on the SEC Dodd-Frank Timeline


SEC Chair Mary Schapiro testified before the Senate Committee on Banking, Housing, and Urban Affairs on September 30, 2010. In so doing she gave more clues on the SEC’s regulatory priorities under the Dodd-Frank Act and timing for rulemaking actions.  OTC Derivatives.  Title VII of the Dodd-Frank Act provides a... Read More

Topics: Banking, Energy, Executive Compensation, Private Equity, Public Companies and Securities