May 5, 2006
Big Drop in Filing Fee Rates Planned for ’07
On Wednesday, in the midst of providing testimony on the Hill, Chairman Cox announced that the SEC would drop fee rates considerably for the next fiscal year – the registration filing fee rate will be reduced by 71.3%! The rate would decrease to $30.70 per $1 million worth of securities registered from the current rate of $107.00.
This new rate will be effective at the beginning of the SEC’s next fiscal year, October 1, 2006 or 5 days after the date on which the SEC receives its regular appropriation, whichever date comes later (and based on past experience, as evidenced by my blogs from prior years, it’s always the latter as Congress inevitably drags its feet in approving the federal budget).
An Open Letter to All Journalists
On CompensationStandards.com, I have posted my “Open Letter to All Journalists,” which is an indirect response to the Holman Jenkins op-ed in Wednesday’s WSJ entitled: “Surprise! CEOs are Still Highly Paid!”
I characterize my response as “indirect” because it is difficult to take Mr. Jenkins too seriously because I believe he will hold onto his views despite his lack of command over the subject matter. For example, Mr. Jenkins blasts pay-for-performance because Mr. Jenkins contends: “Pay for performance” is paying for the past, not the future, which is what stock prices care about.”
As far as I know, that’s not anyone else’s definition of “pay-for-performance.” In fact, pay-for-performance is precisely the opposite of what Mr. Jenkins believes it to be. A company enters into a CEO pay arrangement today with specified future performance targets that need to be triggered in order to earn the pay. But I thought posting my response could be useful to other journalists who need to get up-to-speed on responsible pay practices in the midst of so much misinformation out there on the topic.
Analysis: Comment Letters on the SEC’s Executive Compensation Disclosure Proposal
Last week, Jesse Brill submitted his second comment letter on the SEC’s executive compensation disclosure proposal. This second letter contains analysis of other interesting comment letters and reiterates some of the points made in his first comment letter. Check them out!