TheCorporateCounsel.net

Squeezed in just before the government shutdown – the Federal Register site indicates they are now severely restricting what is being published – the SEC’s pay ratio disclosure proposal was published yesterday in the Fed Reg. So the comment period has officially started – even though a number of comments have already been submitted. It ends in 62 days – on December 2nd.

For recent commentary by SEC Chair White about the status of the other “Four Horsemen” (i.e. outstanding Dodd-Frank governance and exec pay rulemakings), read the entry I just posted on CompensationStandards.com’s “The Advisors Blog.”

Note the SEC has changed the “shutdown” language on its homepage so that it’s no longer confusing by tweaking the sentence that links to its shutdown plan.

Upcoming Webcast: “Doing Your Pay Ratio Homework Now: A Roadmap”

I’ve just put together this CompensationStandards.com webcast for next Wednesday, October 9th (noon eastern) – “Doing Your Pay Ratio Homework Now: A Roadmap” – so you can hear Compensia’s Mark Borges, Deloitte Consulting’s Mike Kesner and Towers Watson’s James Davies, Steve Seelig and Dave Suchsland get into the nitty gritty about how to do the math in the SEC’s pay ratio proposal.

This program will not be an overview of the SEC’s new proposal on pay ratio disclosures–we have posted plenty of memos to get you up-to-speed. Rather, this program will drill down to see where you stand if the proposal was adopted–and to help you decide whether you should consider submitting a comment letter to the SEC using hard facts. So this program will help you evaluate how to choose a compensation definition; how to conduct statistical sampling in this area; how to access the right data and calculate the median.

Then after that webcast ends, join this TheCorporateCounsel.net webcast – “Dealing with the Board: Presentations, Etiquette & More” – at 2 pm eastern on October 9th featuring legends Stasia Kelly of DLA Piper, John Olson of Gibson Dunn and Stewart Landefeld of Perkins Coie.

SEC Pays $14 Million to Whistleblower! Ka-Ching!

Crime doesn’t pay? Whistleblowing sure can! Yesterday, the SEC paid $14 million to a whistleblower. The SEC’s whistleblower awards can range from 10-30% of the money collected in a case.

Kudos to the students in the International Transaction Clinic at the University of Michigan Law School for creating a novel “C-corporation with benefit corporation language” as noted in this Forbes article.

– Broc Romanek