McGuireWoods has provided comments to the SEC on several aspects of the proposed rules to implement the Say-on-Pay provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The proposed rules are summarized here. The comments focus on the practical implications of the proposed rules, given the constantly evolving executive pay practices of public companies, and they provide suggestions to make the rules more meaningful to investors and ease compliance for companies. The comments also address aspects of the say-on-frequency vote and the golden parachute vote.
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