March 15, 2010

The SEC’s New Rules: Corp Fin Issues Three More CDIs

Even though calendar-year fiscal companies are pretty close to finalizing their proxy materials, Corp Fin continues to issue interpretations on the SEC’s new rules. On Friday, these three new CDIs were issued:

New Question 119.25
New Question 119.26
New Question 133.12

In his “Proxy Disclosure Blog,” Mark Borges provides some commentary on these new CDIs.

Something Novel: Proxy Statement Shareholders’ Letter from the Board

We’re all familiar with the glossy annual report’s letter to shareholders from the CEO. But what about an annual letter from the board for the proxy statement? On Friday, Prudential filed its preliminary proxy materials and it includes just such a three-page letter. Plain English, lots of rationale and detail into decisions. Good stuff.

Remember that Prudential also is trying a novel way to increase the level of voting by its registered holders with a novel initiative that ties to its environmental & sustainability program.

What the Top Compensation Consultants Are NOW Telling Compensation Committees

Tune in tomorrow for the webcast – “What the Top Compensation Consultants Are NOW Telling Compensation Committees” – to hear Ira Kay of Ira T. Kay & Company, Mike Kesner of Deloitte Consulting and James Kim of Frederic W. Cook & Co. analyze what types of risk assessments companies are putting into place as well as what are companies doing in the areas of equity grants pay-for-performance and 280G gross-ups.

– Broc Romanek