January 11, 2023
Pay Versus Performance Disclosure: Disclosing Adjustments
Over on the Advisors’ Blog on CompensationStandards.com, John recently noted another nugget of Staff interpretation that relates to the level of detail that must be presented regarding the pension plan and equity award adjustments that are used to determine the amount of “executive compensation actually paid.” The Staff was asked whether the pension value adjustments and equity award adjustments could be disclosed in the footnotes to the pay versus performance table as aggregate amounts, rather than disclosing each of the amounts deducted and added. The Staff confirmed that it expects to see each of the individual adjustment amounts disclosed as part of the footnotes to the pay versus performance table.
If you have received some interpretive advice from the Staff on the new pay versus performance disclosure requirements, feel free to share it with us in the Q&A Forum or otherwise.
– Dave Lynn