The Advisors' Blog

In February, Liz blogged about some pay versus performance disclosures starting to roll in. Those were from smaller companies and—maybe most notably—none of those early disclosures were in a proxy statement. We were anxiously awaiting filings by larger-cap companies. I’m happy to share that a simple EDGAR word search results in quite a few filings since late February.

Personally, I am most interested to see how “real life” examples deal with updated equity award valuation assumptions and the timing of accrued dividends and how much companies provide a narrative explanation if there is a disconnect between compensation actually paid (CAP) and the performance metrics in the PVP table. Check these out to see how they handled whatever disclosure topics you’re struggling with:

Kimberly-Clark Corporation (page 85)

IQVIA Holdings Inc. (page 117)

Raytheon Technologies Corp. (page 84)

Eli Lilly and Company (page 80)

EQT Corporation (page 76)

Kellogg Company (page 64)

The Boeing Company (page 67)

Dow Inc. (page 86)

There are quite a few other large- and mid-cap examples available on EDGAR now too. Hat tip to our Editorial colleague & Fenwick team member Emily Sacks-Wilner, who continues to provide key updates to us all!

This Skadden post on the Columbia Law School Blue Sky Blog highlights a number of disclosure questions that remain after the SEC’s recent CDIs. Hopefully, some of the early filers have disclosed their approaches to these questions, where relevant, through the copious use of footnotes, so we can all see whether a consensus emerges on these topics.

Curious how these are disclosures are being received by investors and the media? It’s probably still too early for many takeaways, but the WSJ reported on some of the above filings—and others—over the weekend.

– Meredith Ervine