The Advisors' Blog

This blog features wisdom from respected compensation consultants and lawyers

June 23, 2022

Clawbacks & Pay-for-Performance: Final Rules Coming Soon?

John blogged this morning on TheCorporateCounsel.net about the SEC’s newly published Reg Flex Agenda for Spring 2022. Even though the Reg Flex Agenda isn’t binding in any way, it reflects the Chair’s rulemaking priorities and can give insight into timeframes for proposals & final rules. Here are the compensation committee & executive pay-related items:

Clawback Listing Standards – final rules in October 2022

Pay v. Performance Disclosure – final rules in October 2022

Human Capital Management – proposal in October 2022

It’s often also interesting to see what doesn’t make it onto the agenda. The potential rulemaking on bank bonuses that I blogged about last December appears to have dropped off, and the 2020 proposal to modernize Rule 701 has been withdrawn. With 53 rules on Chair Gensler’s priority list, he has to draw the line somewhere…

With so many important rules & proposals scheduled to land this fall, you don’t want to miss our “Proxy Disclosure & 19th Annual Executive Compensation Conferences” – to get practical guidance on what you need to do to comply with the new requirements. We have sessions dedicated to clawbacks, pay-for-performance, human capital management, and the deluge of other new developments. Here’s the full agenda for the Conferences – 18 sessions over 3 days. Register today – sign up online, email sales@ccrcorp.com, or call 1-800-737-1271.

Liz Dunshee