June 16, 2009
SEC’s New Interp Changes Disclosure for Performance Share Plan Fair Values
– Paula Todd and Andy Restaino, Towers Perrin
At the end of May, the SEC Staff surprised the corporate community with a new interpretation – in the form of CDI 120.05 – that entirely changes how the “Grants of Plan-Based Awards Table” is to show the Grant Date Fair Value of performance plan share plans in column (l). As we explain in this memo, we think the SEC’s action is misguided – and we hope it can be reconsidered in light of the anticipated broader review of disclosure that SEC Chair Shapiro has planned. Let us know what you think.