TheCorporateCounsel.net

March 14, 2023

The Disclosures Are Here! Early PVP Disclosure Trends Emerge

In a post on the Advisor’s Blog on CompensationStandards.com, Liz highlights the early trends in pay versus performance disclosure courtesy of Compensation Advisory Partners. Their new memo summarizes early trends for S&P 500 disclosures. As we had expected based on our experience with preparing model disclosure, the pay versus performance disclosure is long, ranging from three to seven pages in the proxy statement, with an average of 4.3 pages. Most of the early filers included the disclosure near their CEO pay ratio disclosure, outside of the CD&A. Further, most of the companies used an industry index for their peer group TSR comparison, rather than a self-selected peer group.

For more details, check out Liz’s blog and the Compensation Advisory Partners memo, and you can find more guidance in our “Pay-for-Performance” Practice Area on CompensationStandards.com.

– Dave Lynn