In the “Dodd-Frank Blog,” David Jenson of Leonard, Street & Deinard gives us some indication of what the comment letters submitted to the SEC look like regarding its general solicitation proposal. Interesting stats from the states – as well as anonymous rants and personal attacks – are among those in the comment letters. And as noted in this Business Insider article, even Sen. Carl Levin (D-MI) submitted a terse comment letter (see this Cooley news brief on the Senator’s letter)…
SEC Brings 1st Enforcement Action Against Emerging Growth Company
As noted in this NY Times article, the SEC recently brought an enforcement action against an emerging growth company that looks like was a complete fraud perpetrated by a disbarred lawyer. For those like me that thought Congress rushed the JOBS Act, “we told you so”…
Transcript: “Secrets of the Corporate Secretary Department”
We have posted the transcript for our popular webcast: “Secrets of the Corporate Secretary Department.”
– How Much – General Counsel’s pay reaches $1.4 million. The median total compensation for General Counsels at Fortune 1000 companies, as reported in Equilar’s 2012 Top 25 Survey, was $1,409,982. Chief executives’ pay calculated for 2011 among S&P 500 companies revealed a median total pay figure of $9.6 million.
– Growth Rate – General Counsel’s pay growth outpaces CEOs and CFOs in 2011. For the 136 General Counsels at Fortune 1000 companies that participated in both Equilar’s 2012 and 2011 Top 25 Surveys, median total compensation increased 2.4 percent in 2012 compared to the previous year. In 2011, the increase was 12.8 percent. That growth is more than the 6.2 and 8.9 percent growth of S&P 500 chief executive and chief financial officers over the same time frame, respectively.
– Industry Breakdown – Technology and Media CEOs replace Finance as highest paid industry. Companies in the Technology, Media, & Telecom industry ($1,679,000), Food & Beverage industry ($1,527,000) and Finance & Insurance industry ($1,521,000) paid their General Counsels more than any other industry. Last year, the Finance & Insurance industry had the highest pay. The lowest paid industries in 2012 were Retail & Consumer ($1,146,000) and Business Services ($1,161,000).
– GC vs. Others – The General Counsel role is replacing operational executives in importance. The number of General Counsels identified as named executive officers among the S&P 1500 index has grown from 494 individuals in 2007 to 591 individuals in 2011, a 20.9 percent increase. The importance of the legal position appears to be pushing out the operational executives from the five highest paid positions as the number of chief operating officers and vice presidents of operations have fallen by 13.3 percent, a decrease from 835 in 2007 to 724 in 2011.
– Equity Levels – Most GCs receive at least two types of equity vehicles. 49.9 percent of General Counsels received two unique award vehicles, while 28.6 percent received three unique vehicles. The most common vehicles are time-based stock, time-based options, and performance-based stock which were granted to 63.5, 61.0, and 62.7 percent of the General Counsels, respectively.
– Law School Matters? – Harvard tops all law schools with the most alumni serving in General Counsel roles. The top 3 law schools attended by Fortune 500 General Counsels were Harvard, Georgetown University, and the University of Virginia with 16, 12, and 9 alumni, respectively. Those Law Schools are ranked as number 3, 13, and 7 by U.S. News and World Reports’ Best Law Schools Rankings, respectively. The top ranked schools, Yale and Stanford, did not appear in the top 10.
– Gender Breakdown – More women serve as General Counsels than as Chief Executive Officers. Of the 175 General Counsels disclosed in public proxy filings, 148 were male and 27 were female (15 Percent). 3 percent of chief executive officers among S&P 1500 companies are female .
– Gender Pay Gap? – Male General Counsels receive 6.7 percent more pay than their female counterparts. The difference between median total compensation for male and female General Counsels at Fortune 500 companies was 6.7 percent, $2,263,577 for males and $2,120,764 for females.
Craziest Idea of All Time? “Human Capital Discussion & Analysis”
I’ve held off blogging on this “Human Capital Discussion & Analysis” proposal by the Society for Human Resource Management because the thing was so laughable that I couldn’t take it seriously. But last month, the SHRM issued a second draft of its proposal. Wow!
The SHRM’s proposal would need to be adopted by the American National Standards Institute and would require public companies to prepare a Human Capital Discussion & Analysis, along the lines of the CD&A and MD&A except the focus would be disclosure of almost every corporate cost associated with the hiring, retention, and training of employees and contingent workers, plus detailed information regarding how the company is organized and staffed. I’m not sure exactly how they would pressure the SEC to require this. The HR Policy Association has been keeping track of comment letters submitted on this, etc.
Our New “Business Disclosure Handbook”
Spanking brand new. Posted in our “Business Disclosure” Practice Area, this comprehensive “Business Disclosure Handbook” provides a heap of practical guidance about Item 101 of Regulation S-K. This one is a real gem – 31 pages of practical guidance…
If you’ve interacted with anyone up in the NYC or New Jersey areas, you know how bad it still is for those impacted by Hurricane Sandy. Late yesterday, the SEC posted the following announcement:
In a continuing effort to provide assistance to individuals and entities attempting to comply with filing and other obligations under the federal securities laws in the aftermath of Hurricane Sandy, the SEC today said it is preparing relief measures that would extend filing deadlines for those affected by Hurricane Sandy and its aftermath.
On October 29, 2012, the Commission posted notice on its website that it understood filers may have difficulty making filings and that the staff would handle requests for filing date adjustments on a case-by-case basis. SEC staff are preparing relief measures that are expected to include extensions of filing deadlines for any filing due during the period from October 29, 2012 to November 20, 2012 for publicly traded companies, investment companies, investment advisers, other persons with filing obligations, accountants, brokerage firms, and transfer agents, among others. It is anticipated that the deadline for any such filing would be extended to November 21, 2012, and the scope of the relief measures would extend to any individual and entity with a filing obligation that cannot file timely due to Hurricane Sandy and its aftermath. The staff will also consider requests for additional relief on a case-by-case basis.
Political Spending Disclosure (Like Political Spending) Is on the Rise
Here’s news culled from this Blank Rome newsletter (I know I blogged about this before but bears repeating on Election Day):
The 2010 Supreme Court decision in Citizens United unleashed political spending by corporations and the 2012 elections are expected to be the most expensive ever. The Center for Political Accountability (CPA) and The Zicklin Center for Business Ethics Research recently issued their 2nd Annual Index of Corporate Political Accountability and Disclosure. The Index analyzes the manner in which S&P 200 companies are navigating corporate political spending after Citizens United based on the practices and policies of these companies as publicly disclosed on their websites. The Index sponsors believe that disclosure of corporate spending gives investors the facts needed to evaluate whether such spending is in the best interests of shareholders, identifies possible sources of risk and helps ensure meaningful and effective board oversight.
Highlights of the 2012 Index include:
– Many companies have increased their level of disclosure; of the 88 companies studied both in 2011 and 2012, 85% improved their overall scores for political accountability and disclosure, with the most improved, Costco, going from a score of 3 (out of 100) in 2011 to 85 in 2012;
– Almost half (47%) of the companies studied reported their contributions to candidates, parties and “super-PACS,” 11% reported that they make no such contributions and 42% made no disclosures;
– More than half (57%) provided a full political spending policy on their website, 32% gave brief policy statements and 11% made no such disclosures;
– More than half (56%) reported that the board of directors regularly oversees political spending, 48% reported that a board committee regularly reviews company policy on political spending and 46% said that a board committee reviews company political expenditures;
– Smaller companies were less likely to provide full disclosure of political spending and board oversight;
– The highest scoring companies (based on a scale of 0 to 100) were Merck (97), Microsoft (94), AFLAC (93), Gilead (92) and Exelon and Time Warner (each tied with 88); and
– 18 companies were tied for last with a score of 0.
After all the data is in, we can expect that the amount of corporate political spending in 2012 will surpass all previous records and that there will be continued calls for disclosure. Accordingly, we expect that corporate governance “best practices” will soon require public companies to voluntarily disclose on their websites or through their SEC reports, information on their policies on political contributions and the amounts of such contributions. Companies not presently making such disclosures should consider “electing” to make them in the future.
Wow! Did you see this press release from DTC? Haven’t seen much about it online at all, just this short blurb from the Financial Times:
Trillions of dollars of stock certificates are feared ruined after Hurricane Sandy flooded a vault at the Depository Trust & Clearing Corp, the Wall Street-owned organization that manages important parts of the U.S. trading infrastructure. The DTCC houses 1.3m paper certificates for shares, bonds and other financial instruments, including foreign securities, at the organization’s headquarters in Manhattan’s financial district.
As businesses in the affected areas continued efforts to pump out flooded basements, the DTCC admitted on Thursday that its vault remained underwater and officials had still not been able to assess the damage. “The building itself remains inaccessible and will be until power is restored and an on-site health and safety inspection can be completed,” it warned in an email alert to its clients. It has suspended processing of physical certificates for an indefinite period.
Adding to the confusion, the DTCC also said that it was still trying to track down certificates that were in the mail over the period of the storm. Couriers are experiencing disruptions of their own and could take several days to reroute deliveries to DTCC’s alternative sites. A spokeswoman added that it had electronic records of all the certificates, which could be reissued. “Hindsight is 20/20. We have taken a lot of precautions, in terms of protection both for the security of our systems and of our records, and we have a full inventory of the certificates, as well as a robust recovery plan.”
DTCC is used by the financial industry for clearing and settling trades, and it houses stock certificates so that they do not usually have to be posted around the country from investor to investor. The vast majority of trades are now recorded electronically without certificates moving at all. The organization said that it switched its systems to back-up servers and was dealing with electronic trades as normal out of offices in Dallas, Texas, Tampa, Florida and Brooklyn, New York. More than 1,000 of its New York employees are working from home.
In recent years, the DTCC has spearheaded an effort to encourage electronic-only share and bond issuance, so the proportion of securities that exist in paper form has declined. The organization has further encouraged the process by encouraging “dematerialization”, where certificates are converted to electronic format. In a white paper earlier this year, it said that it cost the financial industry almost $300m to replace $16 billion of certificates that disappeared in the collapse of the World Trade Center in 2001.
A friend claims that stock certificates are printed on special paper that can be laundered – meaning I guess the damage would be minimal. But that doesn’t seem to come out in DTC’s press release (here is the latest on DTC’s operations).
Disney’s Proxy Access Shareholder Proposal
Recently, Disney submitted a no-action request in response to a shareholder proposal on proxy access. It looks like the proposal came from a London-based firm called Legal and General Assurance (Pensions Management) Limited, but ultimately from Hermes Equity Ownership Services (the letter says Hermes is the “client”) which is a European-based fund again that’s active. Maybe this proposal preempted one that I thought Disney got jointly from CalPERS and three other funds…
Meanwhile, Jim McRitchie reports that the United States Proxy Exchange (USPX) has suspended its central activities. USPX was a leader in filing shareholder proposals related to proxy access last season.
Atlas’ Networking Potential
In this podcast, Dave Chun of Equilar explains what Atlas is and how it can help you leverage professional networks (you can try a free trial), particularly for boards, including:
– What is Atlas?
– What was your goal in creating it?
– Any surprises so far since it went live?
Yesterday, I blogged about how Hurricane Sandy could impact your disclosures. Here is more on that topic from Goodwin Procter’s John Newell, particularly for your next Form 10-Q:
Form 10-Q Disclosure and Sandy
Many of our public company clients are preparing to file their quarterly reports with the SEC. This message highlights the possibility that “Superstorm” Sandy is likely to affect these clients in a variety of ways. Although most companies have only just begun preliminary action to assess the impact of the storm, public companies will want to consider possible MD&A disclosure of the potential effects of Sandy, as well as related disclosure and other securities law issues. As a starting point for evaluating these matters, the SEC disclosure principles and related issues that should be considered include the following:
1. MD&A Speaks as of the Filing Date
The SEC has made clear that MD&A must discuss and analyze a company’s financial condition and results of operations, including any known facts, trends or uncertainties, as of the date of filing, rather than the end of the fiscal period covered by the report.
Public companies should therefore consider including MD&A disclosure about the potential effects of Sandy in their Form 10-Q reports for the quarter ended September 30, 2012 if the report is filed after the date(s) on which Sandy affected the company’s business, properties and/or financial status. Note that “risk factor” or other cautionary disclosure alone may not be adequately responsive to SEC requirements for an event that has already happened, even though the impact is currently unknown or uncertain. To the extent that the company’s disclosure includes estimates or other quantitative information, cautionary disclosure about the possibility of that information changing as more facts develop should be considered.
2. Two-Step MD&A Disclosure Test
The SEC has also made clear that the required test for MD&A disclosure of known facts, developments, trends, demands, commitments, events or uncertainties is the test first announced in the 1989 MD&A Interpretive Release. Where a trend, demand, commitment, event or uncertainty is known, management must make two assessments:
First: Is the known trend, demand, commitment, event or uncertainty reasonably likely to come to fruition?
Second: If management cannot determine that the trend, demand, commitment, event or uncertainty is not reasonably likely to occur, management must evaluate materiality objectively on the assumption that it will come to fruition.
Disclosure is required unless management can determine that it is not reasonably likely to have a material effect on the company’s financial condition or results of operations. This test, rather than the Basic v. Levinson materiality test (balancing of probability and magnitude), should be used for this MD&A disclosure.
Since Sandy is for nearly all companies a historical fact at this time, most companies will need to consider the potential effects of Sandy using the second test and include appropriate disclosure in their MD&A disclosure.
Because of the very short interval between the date of the storm and the due date for Form 10-Q reports, it is likely that many companies will be unable to make definitive or specific statements about the effects of Sandy. Among other things, the internal and external resources (such as engineers and insurance adjusters) required to begin a definitive assessment are likely to be subject to extremely limited availability for some time. As a result, it may be difficult for companies to establish reasonably accurate estimates of damages and/or uninsured losses; even approximate estimates or ranges may be difficult at this point and may take significant time to establish. These factors should be considered in drafting any disclosure relating to the effects of the storm.
Although the discussion above focuses on potential disclosure of adverse impacts, some public companies may experience increased demand for their products or services, which could lead to disclosure about possible favorable material effects (for example, building supply, construction and engineering/remediation companies; manufacturers of switches/signals/controls for transit systems; manufacturers of transformers and other components for the power grid). Other companies may benefit from increased consumer spending to replace damaged items, resulting in unexpected positive business developments, while companies whose business relies on discretionary consumer spending (for example, clothing) may see unanticipated negative business developments as discretionary consumer spending is redirected to spending related to storm damage. Each company will need to evaluate the need (and content) of potential disclosure based on its specific facts.
3. Form 8-K Item 2.02 Filing Requirement
Companies should be aware that the reporting requirements of Form 8-K Item 2.02 are triggered by the disclosure of material non-public information regarding a completed fiscal period. If a company releases additional or updated material non-public information regarding a completed fiscal period (for example, if the company issues a press release updating previously-released information relating to a completed fiscal period), that release will trigger an additional Item 2.02 filing requirement.
4. Other Possible Issues
A. Insider Trading. Companies should remember that to the extent that material information develops after the date on which the Form 10-Q is filed they may need to evaluate whether the company’s insider trading policy and applicable SEC insider trading requirements would affect the ability of insiders to buy or sell the company’s securities.
B. Guidance and Projections. Companies should also be aware that the effects of Sandy may cause guidance they give now or have given before to become incorrect. In appropriate cases, companies should consider highlighting the fact that their guidance does not include any estimates for the effects of Sandy. If companies choose to include an estimate for these effects, they should be alert to the possibility that it may be appropriate (or in some cases necessary) to update that guidance as more facts become known.
How to Request a Filing Date Adjustment for a Late Filing
Hurricane Sandy: Should the NYSE Have Been Shut Down?
There has been some debate in the mass media about whether the NYSE should have shut down for two days due to Hurricane Sandy. Here are some of those articles:
Second Circuit Addresses Insider Trading Duty under Misappropriation Theory
In law school, my favorite part of the securities law class dealt with the emerging misappropriation theory. Here is a blog from David Smyth about the latest case, dealing with tipping by those that conducted due diligence for a possible deal…
As with all disasters, the potential impact on your disclosures must be evaluated (Howard Dicker in NYC shares this eye-popping video of flooding). Here is some commentary from Yelena Barychev Blank Rome’s blog on this:
A few SEC filings made this week reflect the effect of Hurricane Sandy ranging from postponing or cancelling quarterly earnings calls to extending the deadline of a tender offer. In addition, in response to Hurricane Sandy, some companies qualify their guidance in earnings press releases by excluding losses due to the impact of the hurricane if a significant portion of the company’s revenues is derived from the areas affected by Hurricane Sandy.
Some forward-looking statements in earnings press releases reference the impact of Hurricane Sandy as one of the risks and uncertainties which could cause actual results to differ materially from those projected.
While we are in the midst of the 10-Q season, companies affected by Hurricane Sandy should also evaluate whether they need to include in Form 10-Q a risk factor related to the potential impact of the hurricane on their results of operations and financial position.
ISS Extends Policy Comment Deadline to November 9th
ISS has extended its deadline to submit comments on its draft ’13 policies to November 9th.
Our November Eminders is Posted!
We have posted the November issue of our complimentary monthly email newsletter. Sign up today to receive it by simply inputting your email address!
Conflict Minerals Poll: Are You Using a Process Design Consultant?
Meanwhile, we had an interesting query in our “Q&A Forum” yesterday (#7397) about whether companies were hiring consultants to help them sort out the design & processes necessary to capture the conflict minerals data. I posted an answer but thought I would poll our readership since this wasn’t in our “Quick Survey of Conflict Minerals” that will wind up soon…
Good scary Halloween stuff, loosely based on the attention placed on the impact of Hurricane Sandy on EDGAR (see my blog about that from Monday). I have heard a few stories about errors in SEC filings recently such as these (please send your own stories – I will keep them confidential unless you tell me otherwise):
– The error in this exhibit to a SEC filing was likely caused by a disgruntled employee (or maybe someone at the financial printer was having fun) as the second resolution in this amendment to City National Bancshares’ certificate of incorporation has swear language buried in the midst of it to the effect of: “you f__ing new when i asked you liartors…”
– Reminds me of a time around 20 years ago when someone I was working with did the same thing and filed an S-4 with the “Securitzed Exchange Ommission.” Never occurred to anyone to read the very first line of a 200 page document.
– A fake Silicon Valley Form S-1 from a company called “Ponzify, Inc.” with lots of comedy such as: “For instance, “Our company is built upon a viable revenue model” is a forward-looking statement.”
And here is an excerpt from the fake Business Section: “Our primary measurement of revenue is a non-GAAP accounting principle known as Adjusted Consolidated Assumed Income (ACAI). ACAI is an ancient accounting remedy that can slow the aging process of most balance sheets and rejuvenate the face of any company, no matter what the medical community or the FTC might tell you.”
– I scared myself when I plugged the “F” word into Edgar’s search engine and got some hits. But that’s because the prospectus for Audience Productions includes the screenplay for a movie entitled “Lydia Slotnick Unplugged.” I’m not sure why the screenplay was filed but there you have it…
CII’s Halloween Request to Top Bar Associations: No More “Zombie” Directors
Last week, CII issued this press release indicating that it wrote letters to the American Bar Association and the Delaware Bar Association urging them to revise their voting standard to a majority vote. In the letters, CII provided draft language and supporting commentary.
We continue to post new items daily on our blog – “The Mentor Blog” – for TheCorporateCounsel.net members. Members can sign up to get that blog pushed out to them via email whenever there is a new entry by simply inputting their email address on the left side of that blog. Here are some of the latest entries:
– Earnings Call Disruptions: Why Don’t They Happen More Often?
– NLRB’s New Restrictions on Social Media Policies
– Food for Thought: The Audit Committee’s Dilemma
– Sarbanes-Oxley and Audit Reform
– Insider Trading: Open Window Trading Periods Not Mandatory
Recently, Microsoft filed its 2012 proxy statement. The upshot is that the company continues to evolve its approach, although most changes year-over-year are mostly cosmetic. But put 2011 and 2012 side-by-side and they look quite a bit different. Here are some of the changes:
1. Adopted the graphical look and feel of new corporate-wide branding guidelines (e.g., font, color, captioning). Moved to 2-column text for improved readability.
2. Continued to work on organization of content so that it flows more naturally and related parts are grouped together.
3. Highlighted on the cover that for the first time they are moving to proof of ownership for admission. They emphasize the point several other places.
4. Included an easy-to-understand table showing the vote needed for ballot items and effect of abstentions and uninstructed votes (pg. 3)
5. Described a political contributions disclosure policy (pg. 6)
6. Revised the graphical presentation of charts and graphs that they had used previously:
– Microsoft operating income vs. total direct compensation (pg. 25). The table illustrates that changes in total direct compensation for NEOs generally have tracked changes in our operating income over the last 5 years.
– Microsoft’s position relative to peers on three measures — revenue, market capitalization and headcount – (pg. 27). The chart represents the company’s current position relative to combined peer companies on three dimensions, to demonstrate the complexity and scope of their responsibilities.
– Pay mix versus peers (pg. 28). The chart provides information about the company’s fiscal year 2012 target pay mix for our NEOs (excluding Steve Ballmer) compared to the non-CEO NEOs of their Dow 30 and Technology peers companies.
– CEO pay comparison (pg. 29). The table illustrates Steve Ballmer’s compensation opportunity for fiscal year 2012 compared to his peers.
The SEC’s (& EDGAR’s) Status During Hurricane Sandy
On days like this – where the SEC’s HQ is closed but it’s other office locations are open (at least those out of Sandy’s path) – I wonder whether there should be someone responsible for managing the SEC’s website and other communication functions outside of DC for these one-off situations. The SEC now has Hurricane Sandy info posted on its home page – and here is info for Edgar filers. Corp Fin is operating like during a snowstorm (see this blog) – which Dave has confirmed in response to a query in our “Q&A Forum” (#7393).
Alan Dye has addressed Section 16 filing deadlines in his Section16.net Blog today. In addition, some members report they have been able to file on Edgar so far today – but note this statement on the SEC’s site:
During this weather emergency, we understand that filers may be unable to submit their filings. You should file when you are able. The Divisions will handle requests for filing date adjustments on a case by case basis.
As this article notes, it’s the first time in 27 years that the NYSE has been closed due to weather!
Troutman Sanders’ Brink Dickerson gives us this news: Recently, a court in the Western District of Missouri held that the PCAOB privilege applies – not only to material exchanged with the PCAOB and records of exchanges – but also to internal documents of the corporate client that reflect development of material and information for the PCAOB audit or investigation, because those materials were created because of the PCAOB action. The privilege may be asserted by the subject firm, as well as the PCAOB. This Bennett v. Sprint Nextel & KPMG decision is important because it is contrary to Silverman vs. Motorola, a 2010 Northern District of Illinois case that held that the privilege covered only documents and information prepared specifically for PCAOB.
Note that under §7215(b)(5)(B), without loss of the privilege, the material may be shared with other federal and state regulatory and enforcement entities.
Federal Court Applies SOX/Dodd-Frank Whistleblower Protections to Non-Securities Law Circumstances
In his CompensationStandards.com blog, Mike Melbinger notes how a federal court recently allowed a whistleblower case under Sarbanes-Oxley and Dodd-Frank to proceed even though it related to an employee’s complaints about a qualified pension plan – not a securities law area.
More on “The Mentor Blog”
We continue to post new items daily on our blog – “The Mentor Blog” – for TheCorporateCounsel.net members. Members can sign up to get that blog pushed out to them via email whenever there is a new entry by simply inputting their email address on the left side of that blog. Here are some of the latest entries:
– Even Domestic Bribery Falls within the SEC’s Jurisdiction
– Delaware Allows $600 Million Caremark Claim To Proceed Against Allergan Directors
– Large Auditors Lobby Like Never Before
– Insider Trading: Three Thoughts about Rajat Gupta
– SEC Approves FINRA Rule Requiring Filing of Private Placements
Spanking brand new. Posted in our “Shareholder Proposal” Practice Area, this comprehensive “Shareholder Proposal Handbook” provides a heap of practical guidance about Rule 14a-8. This one is a real gem – 206 pages of practical guidance. This is an update of a treatise that I co-authored with Beth Young and Bill Morley over a decade ago…
Where Should Lawsuits to Challenge a SEC Rulemaking Be Filed?
In the wake of the news of a lawsuit being filed against the SEC over its conflict minerals rulemaking in the US Court of Appeals for the DC Circuit, I received a few emails from members asking why this case wasn’t filed in the lower court like the resource extraction lawsuit a few weeks earlier.
That’s because the earlier resource extraction lawsuit also involved this emergency motion with the higher court to determine which court has jurisdiction. This emergency motion is slated to be determined on November 7th. This dual track approach over the resource extraction rules likely was taken due to the DC Circuit previously declining to exercise jurisdiction over a challenge to the CFTC’s position limits rule a few months ago. Recall that the proxy access lawsuit was filed with the higher Court of Appeals…
In the conflict minerals case, an amended petition for review was filed on Tuesday to add the Business Roundtable as a petitioner.
Announcing the NASPP Career Center
If you are looking to fill a job opening or a stock plan professional seeking a new position, check out the new “NASPP Career Center.” Any employer (NASPP member or not) can post an industry-related position – and active NASPP members can post a resume profile for visibility to employers looking to fill job openings; resumes are searchable by those with access to the Career Center.
