April 28, 2015

Survey Results: Currency Fluctuations for Incentive Compensation

Thanks to those that participated in this survey – a hot topic! Below are the results from my recent survey on currency fluctuations for incentive comp:

1. Does your company adjust incentive goals/results for currency rate fluctuations?
– Yes, as a policy consistently applied – 24%
– Occasionally, as ad hoc decisions made across years – 15%
– No, we never do – 42%
– Not sure, it hasn’t come up – 20%

2. If your answer to #1 above was “yes,” what is the percent of impact currency rate fluctuations must have for neutralization (i.e. what is the swing/change in the metric due to the currency fluctuation before things get adjusted)?
– Less than 5% – 62%
– 5% to 9% – 10%
– 10% to 14% – 14%
– 15% to 19% – 0%
– 20% to 24% – 14%
– 25% or more – 0%

3. If your answer to #1 was “occasionally” or “never,” are your incentive compensation performance measures predominantly return measures?
– Yes – 32%
– No – 66%
– Not applicable (we don’t use performance measures for our incentive compensation) – 2%

4. If your company makes ad hoc decisions, is the issue decided on whether management raises the issue & how large the impact is?
– Yes – 42%
– No – 8%
– Not sure, it hasn’t come up – 50%

5. If you do adjust your incentive goals/results for currency rate fluctuations, to which type of incentive programs are these adjustments made?
– Short-Term – 61%
– Long-Term – 6%
– Both Short-Term & Long-Term – 33%

Take a moment to participate in our “Quick Survey on Hedging Policies” and our “Quick Survey on Board Portals.”

Will California Require Notice Filings For Regulation A Offerings?

This blog by Keith Bishop notes how the California Commissioner has yet to adopt a form of notice regarding Tier 2 offerings under Regulation A…

My good friend Barbara Blackford – well known in the Society of Corporate Secretaries – is riding 2500 miles on a bike to benefit “Cycling for Good.” You’ve read before in this blog about Cleary Gottlieb’s Julie Yip-Williams (see her blog about her battle with cancer). Next week, Barbara is riding for Julie and a colony cancer research foundation. Barbara is maintaining this blog – and here’s a description of the ride. Most important is this explanation of “Cycling for Good” and how you can donate

Even More on “Subway Marketing to the SEC Continues”

Just after I blogged about additional poster ads in the DC subway system, I found two more new ones – at a subway station that is not even near the SEC (ie. Metro Center station):



– Broc Romanek