April 14, 2022
401(k) Contributions: Tabular Disclosure Requirements
A member recently posed this question in our Q&A Forum (#1408):
If an NEO at a SRC is contributing to a 401(k) plan, or a foreign equivalent, from their salary, would that be accounted for under the Salary column in the Summary Comp Table, or would it have to be separately accounted for in another column?
John responded:
If it’s just a contribution from the NEO, there’s no separate reporting, because the amounts contributed to the 401(k) plan were already reported in the salary column. If the company is making matching contributions, those are reported in the “All Other Compensation” column.
Also remember that Lynn & Borges’s “Executive Compensation Disclosure Treatise” is posted online for members of CompensationStandards.com – and there’s a chapter devoted to the Summary Compensation Table.
– Liz Dunshee