August 23, 2010
Dodd-Frank: SEC Begins Receiving Comments on Executive Compensation Matters
– Broc Romanek, CompensationStandards.com
As I blogged a few weeks ago, SEC Chair Schapiro announced that the SEC would go the extra yard ahead of its blistering rulemaking schedule and start accepting comments on its various projects right away through this Dodd-Frank comment page. The comment letter page is broken up by the Titles in the new legislation, with 31 separate areas for comment, including a section under Title IX which covers the governance and executive compensation provisions. Each rulemaking will have its own comment period as usual – and as required by the Administrative Procedures Act – but this “field day” may help to shorten the comment periods and get rules in place before next year’s proxy season.
When I blogged all that, I didn’t think that the SEC would receive much in the way of comments ahead of specific proposals. But the first few comment letters have started to dribble in on the executive compensation stuff, including this one from Frederic W. Cook & Co.