We just mailed the November-December Issue of The Corporate Executive, which includes a comprehensive recap of important things said at our recent “6th Annual Executive Compensation Conference,” among other things:
– Treasury Speaks about Executive Pay
– Consultant Independence and Accountability
– Fixing Benchmarks and Internal Pay Equity
– Say-on-Pay and Plan Design
– Risk Assessment & Pay
– What Compensation Committees (and Consultants and Counsel) Should Now Be Doing
– Hold-Through-Retirement and Clawbacks
– How to Implement Say-on-Pay Successfully
– SEC Staff: No More “Free Passes” on Material Noncompliant Disclosure
– One Final Reprieve on Section 6039 Returns–And Our Guidance
– Trap for the Unwary: Grant Date Under Section 423
– Section 162(m): The Buck Stops Here
Act Now: As all subscriptions expire in two weeks, please renew now for 2010 – or try a no-risk trial if you are not yet a subscriber.
What is the “Shareholder Communication Coalition”?
Recently, a mailing by the Shareholder Communication Coalition to the CEOs of the S&P 500 – asking for general support on proxy plumbing issues – led a number of members to ask me for more information about this organization. In this podcast, I caught up with Niels Holch, Executive Director of the Shareholder Communications Coalition, to learn more about the activities of the Shareholder Communication Coalition, including this white paper that outlines the Coalition’s recommendations for reforming the proxy voting and shareholder communications system:
– What is the Shareholder Communication Coalition? How – and why – was it formed?
– What has been its focus to date? Can you tell us about the letters that some CEOs recently received?
– Any other activities on the near horizon?
– How can members of the associations involved in the Coalition give their input to the Coalition? Where can people sign-up for email alerts to keep up with Coalition activities?
SEC’s Rating Agency Regulatory Scheme Heighten Risk of Insider Trading
You can’t imagine how difficult it is to draw up rules and cover all the possible implications until you try it yourself. There is always some unintended consequence hiding around the corner. That’s why federal agencies are required to allow the public to comment on proposed rules.
A few months ago, Floyd Norris nailed what he thinks is a crucial flaw in the SEC’s attempt to regulate the rating agencies in this column. Here is an excerpt from that column:
It did that in the name of reforming the credit rating agency system. The new rule shows the dangers of trying to solve one problem without thinking about others. At the heart of the problem is that it is legal for companies and other issuers of securities to give confidential information to rating agencies. Back before the crisis, the fact the agencies had access to such information served to enhance the respect given to their opinions.
Now we know that the major rating agencies — Standard & Poor’s, Moody’s and Fitch — disgraced themselves in rating structured finance products. They relied on bad assumptions, and in some cases may have been lied to by issuers. Their models turned out to be spectacularly wrong. A lot of people think a root cause of the problem was the conflict of interest created by the fact the agencies were paid by the creators of those products, and therefore were dependent on their good will for additional business.
But regulators are unwilling to outlaw the old system, in part because that would leave investors without access to ratings unless they paid for them. So the solution chosen by the S.E.C. is to encourage other rating agencies to rate the products. The rule adopted last week says that whatever information is given to the agency hired by the issuer to rate the structured finance security must be given to other rating agencies, including those that provide analyses only to investors who pay for them.
The result will be that analysts for the other rating agencies, like Egan-Jones Ratings, will have access to information not available to the general public, and their analyses will go only to clients. Those clients will have the benefit of nonpublic information, or at least of their agent’s analysis of what it means.
With insider trading so much in the news lately, it’s worth recalling that back in the summer there was a fuss that members of Congress are permitted to trade with knowledge of nonpublic information (see this recent WaPo article). In fact, there was even a “Stop Trading on Congressional Knowledge Act” bill floated to close the “loophole” that allows members of Congress to trade even when they have access to nonpublic information. I am told that this is not the first time that efforts have been made to change the ethics rules and hold Congress to more of a corporate standard.
Hearings were held in July on this topic, as noted in this article (and here is the testimony given) – but I don’t believe the bill has gone anywhere since. ProCon.org has a resource page about whether insider trading by Congress should be allowed.
The SEC’s Enforcement Division continues to track down bankers and lawyers who are engaging in insider trading. For example, see this recent action against a former law firm lawyer – and this new one against some bankers.
New SEC Filing Fees: Effective on Monday
On Wednesday, President Obama signed the government’s appropriations bill that includes funding for the SEC. As a result, as noted in this SEC advisory, the new registration statement fee rates take effect as of Monday. As announced a while back, the fee rate will increase to $71.30 per million dollars from $55.80 per million, a 28% hike.
More on our “Proxy Season Blog”
With the proxy season now looming in many of our minds, we are posting new items regularly on our “Proxy Season 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:
– RiskMetrics’ 2009 Proxy Season Scorecard
– Remuneration Reports Receive More Dissent in Australia
– Study: “Private Ordering” is Not a Viable Alternative to Proxy Access
– Walden Asks Broadridge Not to Eliminate In-Person Shareholder Meetings
Not only did the SEC adopt new proxy disclosure enhancement rules yesterday at its open Commission meeting, it actually posted the adopting release later in the day (a same-day practice that the PCAOB follows often). Here is the SEC’s press release – and the SEC Chair’s opening statement. We are posting memos regarding these new rules in our “Law Firm Memos” Portal, with a direct link to these memos from our “Hot Box” on the home page.
The Big Question: When Do the SEC’s New Rules Take Effect?
The reason for the hurry is simple – these new rules apply to the coming proxy season as they are effective February 28th. My guess is that the effective date is pushed out so far because a “major” rulemaking requires a 60-day waiting period before implementation – and perhaps the SEC has deemed this a “major” rulemaking (or the OMB forced that determination upon the SEC). The “major rule” determination comes out of SBREFA – the “Small Business Regulatory Enforcement Fairness Act.”
Unfortunately, the SEC barely addressed the issue of compliance dates during its open Commission meeting – and then continued to be opaque in the adopting release (the release says nothing about effective dates other than the February 28th date on the cover). During the course of yesterday, I easily received over 100 emails and calls on this topic and continue to do so. So I imagine Corp Fin is receiving many more.
We are assuming that the February 28th effective date applies to the filing of proxy statements, not the annual meeting dates. Since there is no transition discussion in the adopting release (as Mark Borges has blogged), I’m not sure how this effective date applies to preliminary vs. definitive proxy statements for those that straddle both sides of this date. Or what about companies that file their Form 10-Ks in early February who decide to include the Part III information when they file? If you decide to voluntarily comply beforehand, do you also need to comply with the old rules (only issue is whether to use new or old SCT rules)? I’ll update this blog as we find out more on this critical topic.
I know complying with these new rules is gonna be a real bear for those of you that need to revise D&O questionnaires – or send out supplemental ones – so we just pushed up our CompensationStandards.com webcast to January 7th – “The Latest Developments: Your Upcoming Proxy Disclosures – What You Need to Do Now!” – featuring Mark Borges, Alan Dye, Dave Lynn and Ron Mueller. And to handle the other new SEC rules that don’t deal with compensation issues, we just announced a companion webcast on TheCorporateCounsel.net – “How to Implement the SEC’s New Rules for This Proxy Season” – featuring Marty Dunn, Amy Goodman, Ning Chiu, Howard Dicker and Dave Lynn to be held on January 6th.
The Surprise: Disclosure of How Diversity Is Considered in the Director Nomination Process
Much of the SEC’s rulemaking was anticipated (although the timing was feared – I bet more than one holiday plan has been ruined), but I’m not sure many expected the SEC to adopt its proposal to require disclosure of how diversity is considered in the director nomination process. I imagine boards will be adopting diversity policies in the very near future so that they have something to disclose…we’ll be discussing this during our January 6th webcast.
More on “SEC Re-Opens Proxy Access Comment Period: What Does It Mean?”
Two days ago, I blogged about what the SEC’s “re-opening” of the proxy access period might mean. I have been troubled by the possible conflicting meanings between what the SEC’s press release on the matter says – and what is stated in the extension release.
And here is my conclusion after further pondering: the comment period is not really “re-opened,” meaning that the SEC is not seeking hordes of new comment letters on its proposal. Rather, I think the SEC seeks something more limited in scope – they only want folks to focus on commenting on the “additional data and related analyses” (eg. costs) provided in the comment letters received so far, particularly these three from third-parties mentioned in the extension release:
The SEC also wants comments on this new study from its Division of Risk, Strategy & Financial Innovation regarding share ownership and holding patterns (the data was derived from Schedule 13Fs filed with the SEC).
So as strange as “commenting upon the comments” may seem, the SEC is probably trying to ensure it gets all the facts straight (and that its own study is officially in the rulemaking record) before it rulemakes in a very controversial area…
Poll: How Many Proxy Access Comment Letters This Decade?
Take a moment to participate in this anonymous poll about how many comment letters have been submitted to the SEC on its various reiterations of proxy access proposals since 2003 – the total does include form letters (I’ll post the answer after the holidays):
In this podcast, Dave Lynn and Marty Dunn weigh in on the latest developments regarding shareholder proposals and transparency of the SEC Staff’s positions – as well as discuss muscle cars.
Speaking of Staff transparency, here are slides regarding areas of frequent comment from the Corp Fin Staff to financial institutions that were presented by the Staff at last week’s AICPA Conference.
Another US Supreme Court Case: Conrad Black’s Fraud
The day after I went to the Supreme Court, Conrad Black’s fraud case came before SCOTUS as a test case to determine whether the “honest services” clause (ie. deprive[s] another of the intangible right of honest services) in the wire and mail fraud statute is so broad that it should be invalidated. Here is the transcript of that case’s oral arguments – and here is a blog analyzing the arguments: ” When Is Fraud Really Fraud? The Case of Conrad Black.”
Canadian Securities Regulators Decide Not to Overhaul Corporate Governance Regime
Here is an excerpt from this Tory’s memo: “Canada’s securities regulators have decided not to proceed with the overhaul of our corporate governance regime proposed last December. The proposals would have introduced a more principles-based regime focusing on disclosure in relation to nine high-level corporate governance principles and eliminating the bright-line tests in the current definition of independence, leaving independence determinations to the reasonable judgment of the board of directors. In so doing, the proposals would have moved Canada’s corporate governance regime further away from the U.S. regime, which focuses increasingly on mandatory requirements.”
Yesterday, the SEC issued this press release to extend the comment period on its proxy access proposal for another 30 days. The original comment period ended on August 17th.
For the most part, the press release seems like a formality since the SEC had previously announced back in October that it didn’t intend to consider adopting final rules in this area until early next year. And the SEC regularly takes into consideration comment letters that come in after a comment deadline.
This action may mean absolutely nothing. Or maybe the SEC is being extra careful about meeting the dictates of the Administrative Procedures Act since litigation over this rulemaking has been threatened (and even stronger authority from Congress doesn’t help with the APA). Or perhaps it signals some increasing willingness to consider an “opt out” – the related formal extension release lists four specific comment letters it has received as items that the public may wish to comment upon (as well as the other 500-plus comment letters received so far).
Or maybe this will set the SEC back even further on their rulemaking timetable for proxy access (even with a short 30-day comment period) – since it takes the Staff time to process new comment letters – and this would delay the SEC’s consideration of these rules until legislation is passed providing stronger authority for their ability to rulemake in this area…
Proxy Access: Do You Need to Re-Submit Your Comment Letter?
For those that have already commented, you do not need to resubmit your comment letter – your existing letter is already on file and will be contemplated. However, the SEC is seeking comment on the letters already submitted – including the four noted in their extension notice – so if you feel strongly about this rulemaking, you may want to consider sending in new thoughts on those. But don’t just submit the same letter you already submitted – that won’t make you a fan of the Staff…
Factors to Consider Before Ordering a NOBO List
In this podcast, Rachel Posner of Georgeson digs into the intricacies of ordering a NOBO list, including analysis of the factors to consider when deciding whether to order one.
On Friday, the House of Representatives – by a vote of 223-202 – passed the “Wall Street Reform and Consumer Protection Act of 2009” (it appears that this will be referred to as the “Wall Street Reform Bill”). As I’ve blogged, this bill consolidates and revises numerous reform bills that have been introduced in the House this Fall (eg. Title I contains what was the Financial Stability and Improvement Act of 2009). As of the start of last week, there were 238 amendments offered to this bill.
I’m not convinced I’ve seen a final copy of the bill actually passed since so many amendments were at play. I believe its changed since this version that was floated heading into last week – but that old version is what is linked to from this press release announcing the passage of the bill. [I’ll blog if a newer version becomes available]. We will be posting memos analyzing the bill in our “Regulatory Reform” Practice Area.
Now, the House bill will have to be reconciled with any financial reform legislation that emerges from the Senate. Senator Dodd introduced a reform bill a few months ago – but his bill has encountered opposition and remains in the Senate Banking Committee. Senate action is expected early next year and I imagine some of the House bill’s provisions will not square with the Senate’s version…
FEI’s “Financial Reporting Blog” summarizes the accounting implications of this bill.
House Passes Internal Controls Relief for Smaller Companies
Among the numerous provisions of the House’s reform bill is the Adler-Garrett amendment, which is a permanent exemption for small issuers (those with less than $75 million in public float) from the outside auditor attestation requirements of Section 404 of Sarbanes-Oxley (and have the GAO and SEC study enlarging the exemption for companies with a public float up to $700 million). On Friday, the House voted 271-153 against an amendment offered by Rep. Paul Kanjorski to remove the smaller company exemption.
Politics As Usual: A Poll on the House Bill
I chuckled when I read this quote from Rep. Nancy Pelosi about the House’s action: “The legislation says very clearly to Wall Street: the party is over.” It’s clear that the bill will impact all of us in some way – it is quite comprehensive – but it’s a falsehood to say the party is over. Hasn’t she seen “Animal House”? Recall this quote from John Belushi’s Bluto: “Over? Did you say “over”? Nothing is over until we decide it is! Was it over when the Germans bombed Pearl Harbor? Heck no!”
The Republicans issued this press release says this bill will destroy jobs and the economy. And see this press release from Rep. Barney Frank from before the House vote. The politics is at full throttle. But don’t take my word for it, participate in this anonymous poll and weigh in:
Continuing our proxy solicitor podcast series, in this podcast, Scott Winter of Innisfree provides some insight into how e-proxy intersects with proxy contests, including:
– Can you provide an overview of how notice & access works in a proxy contest?
– How common is notice & access in a proxy contest?
– Will the proposed amendments to the notice and access rules increase use of notice & access by dissidents?
– Should companies or dissidents utilize notice & access in a proxy contest?
The SEC’s E-Proxy Proposal: Comment Letter Fatigue Setting In?
With the deadline for comments on Corp Fin’s proposal to tweak e-proxy behind us, it may surprise you to learn that only two dozen of comments were submitted to the SEC, with the vast majority coming in after the deadline. [Based on the description of the items to be considered at Wednesday’s open Commission meeting, I don’t think this proposal will be acted upon then – although I guess it’s possible that this proposal falls within the term “other corporate governance matters.”]
Then again, it might not surprise you given there is so much other stuff going on – so the more “minor” proposals get buried. Even though we are in the early innings of reform in the wake of the financial crisis, folks might also be experiencing an early case of comment fatigue. I remember the same thing happened during the spate of SOX rulemaking in ’03 – by the end of several dozen proposals, folks had trouble commenting on the last half dozen of the proposals…
A Bunch of International Reforms
The wave of financial reforms sweeping this country is not unique; there are reforms taking place all over the world. Here is a sampling:
– In the UK, the final Walker Review recommendations were recently issued. This is a sweeping governance reform of the United Kingdom’s financial industry, including strengthening the role of non-executive directors and giving them new responsibilities to monitor risk and compensation.
– CalSTRS became the first US-based fund to endorse the United Kingdowm’s “best practices” code for investors that I blogged about last week. Notably, the Walker recommendations urge that this “Code on the Responsibilities of Institutional Investors” should be ratified by the UK’s Financial Reporting Council and become part of that country’s Stewardship Code.
– As noted in this article, the UK’s Financial Reporting Council has issued a set of proposals to reform the UK’s corporate governance regime. What was previously called “The Combined Code” will become “The UK Corporate Governance Code” – subject to what they call “consultation” – and will apply to all listed companies with a “Premium Listing” for fiscal years beginning June 29, 2010, regardless of the country of incorporation.
– India’s review of corporate governance prompted by the Satyam scandal is now expected to result in the issue of corporate governance guidelines by the end of December. Thanks to Jim McRitchie of CorpGov.net for spotting this one (and the two directly above) for me.
Even though I loathe lists generally, I’ll admit that I’ve become obsessed with the voting going on between the fine blogs that comprise the ABA Journal’s Blawg 100. As I blogged last week, our blog has made that list for the second year in a row – and this is the first year that the ABA Journal is putting the Blawg 100 head-to-head in a round of voting.
Well, we have felt the love and we currently stand in 1st place! We are just barely ahead of “Above the Law” (which has an advantage due to the ABA Journal’s design of its voting pages into separate categories – their blog is on the main voting page and ours is not. Many folks have emailed saying they couldn’t find ours in the list; our blog is in the “Practice Specific” category; their’s is in the default “News” category.)
Voting continues until the end of this month – so please vote if you can. It’s a tight race against some tough competition – so every vote counts. To help you navigate the ABA Journal’s voting framework, here are the three steps you should take:
1. Register to vote – it’s free (if you’re an ABA member, your ABA id/password won’t work for the ABA Journal’s site).
2. Take your User Name and password – you will create these when you register – and log-in. This may happen automatically when you click on the link within the email sent to you after you register.
3. Now vote in this “Practice Specific” category by scrolling down to the description of our blog – 2nd blog from the bottom – and clicking the “plus sign” in the box to the left of it (if you don’t see a “plus sign,” you’re not logged-in). If you can’t find our blog, you’re probably in the default “News” category. Click on over to the “Practice Specific” category to find ours…
If you’re having troubles, please shoot me an email and let me know. Thanks for the support!
A Campaign Video: Bringing It!
Enjoy this silly video seeking votes – it’s only 30-seconds long:
SEC to Adopt New Executive Compensation Rules Next Wednesday
Yesterday, the SEC issued a notice that it will hold an open Commission meeting next Wednesday, 12/16 to consider adoption of its executive compensation and other corporate governance proposals. It’s unknown at this time whether they will apply to the upcoming proxy season.
I attended the US Supreme Court’s oral arguments on Monday to hear the fate of the PCAOB argued in FEF and Beckstead & Watts v. PCAOB. It was my first time visiting the land’s highest court. For those that haven’t been, here are 10 take-aways:
1. Simply Wow; A Real Patriotic Experience – Having been to numerous Congressional hearings and other “official” DC meetings, nothing else compares. I could literally feel the history of the country in the room. And I was proud that we have such sharp minds on the bench, even though I don’t agree with all of the views expressed. A “must” for any lawyer, and really any US citizen.
2. How to Attend – I enjoyed the perks of my journalistic hat and obtained a press pass. But even though seating is limited, the main room holds 400-500 and many left after the PCAOB hearing – so it would have been easy to come in and hear the second case. Here is an explanation of how to get in. I saw a number of PCAOB and SEC Staffers in the audience – they got in the same way as the general public. I understand that the cafeteria is open to the public – and it smelled good!
3. Oyez, Oyez, Oyez – When the Justices come into the room – entering simultaneously from behind curtains like magic – they are not announced by their individual names. Instead, they are introduced as a group – followed by three chants of “Oyez’s” by the Court’s Marshall. “Oyez” is sort of an old English tradition. Here is a recording of what that sounds like. Silence by the audience is requested and observed, except for several occasions when something funny is said and there is laughter (ie. a live studio audience). At the conclusion, only one person forgot to observe the request to remain quiet and clapped.
4. Entry into the Supreme Court Bar – The first order of business is the swearing-in of new members of the exclusive Supreme Court Bar. Only those admitted to this bar are permitted to argue before SCOTUS. It’s a pretty small group that does – even though the admission process appears easy – you fill out a form with two sponsors, provide a certificate from your state bar and pay a fee. The problem is that the bar is so small that it’s hard to find two existing SCOTUS bar members to sponsor you. That’s one reason why nepotism happens frequently (although I imagine the practice of parents sponsoring their children is primarily ceremonial as the real SCOTUS bar is dominated by a much smaller subgroup as noted in this paper).
5. Questioning is Pointed – One of the reasons why a visit to hear oral arguments is interesting is that it’s action packed. The lawyers arguing their cases are frequently interrupted by the Justices. It’s not rude – it’s just that time is limited and this is the way it works. During the PCAOB arguments, each advocate didn’t get more than 60 seconds into their opening remarks before they got hit with their first question.
6. Fun Factoids – Very rarely during the 75-minute hearing (it went 15 minutes over) did the term “PCAOB” get mentioned – only 5 times. The PCAOB was often referred to as the “Accounting Board.” And “Sarbanes-Oxley” didn’t get mentioned at all. Don’t believe me? Check the transcript.
7. No Electronics – No electronics of any kind are allowed in the hearing room. Actually, very little of anything. I was allowed to bring in a pad and a pen since I was press. Four sketch artists were drawing to the left of me – probably commissioned by some of the lawyers presenting the arguments (my mom is an artist and has been commissioned to do so in the past).
8. Only One Woman on the Walls – As well known, the Supreme Court has been dominated by white men over its 200-year plus history. As a result, the portraits hanging on the walls reflect that history. With one exception (there could have been more, I didn’t do a comprehensive search), there is a portrait of “Mrs. Roger Taney.” Her own first name is inscribed in small letters underneath (ie. Anne). Poor woman is subjugated to her husband even in death.
9. Building Being Modernized – Although it was hard to tell, posted signs indicate that the Supreme Court building is being modernized for the first time since it was completed 75 years ago. It’s a tremendous building – beautiful through and through. Nice marble walls in the bathroom (Best public bathrooms in DC? The Mandarin Hotel by far).
10. Transcripts Available – Recently, the US Supreme Court began posting same day transcripts of oral arguments. Here is the transcript from the PCAOB case.
Bob Monks recently blogged about his experience of attending the SCOTUS’ Jones v. Harris oral arguments…
Chief Justice Roberts: Examines Intersection of PCAOB and Public Companies
As noted on page 38 of the transcript, Chief Justice Roberts asked several questions about the power of the PCAOB to compel a public company to respond to a PCAOB investigation. Solicitor General Lagan hedged her answer, but essentially said the PCAOB could go to the SEC to obtain a subpoena for this purpose. They were both off the mark a little bit here.
As I’ve been blogging for a long time (also see this
I don’t know why, but sometimes a news story will remind me of a song. This fantastic lead – and lengthy – artlcle from Sunday’s Washington Post about how Neel Kashkari recently resigned as Special Inspector General of the TARP funds reminded me of this Paul McCartney song. Seven months ago, 35-year old Kashkari was tapped to serve as SIGTARP by then-Treasury Secretary Paulson, hired out of Goldman Sachs (but not “lured” out of there; Paulson didn’t know him – Kashkari sent his resume in cold!).
As the WaPo article explains in great detail, Kashkari and his wife have now moved about as far from DC as possible, living a simple life in a log cabin in Truckee, California in what he calls his “Anti-D.C. Sanctuary” (my brother-in-law used to work in Truckee’s hardware store; I’ve been there and its beautiful, just outside of Lake Tahoe). I don’t blame him. Once you see what goes on inside the Beltway – is it the same on Wall Street? – it makes you want to run and hide. And more often than not, Congress is the primary cause for bewilderment as so aptly reflected by this article excerpt:
Soon he was marking hearing dates on his calendar: “BEATING ON THE HILL.”
But don’t feel too bad for Kashkari. He’ll make a mint if he decides to write his own book (rather than just edit Paulson’s, which he is doing right now). So I would just chalk this up as a companion piece to my recent blog, “Can We Just Go Home Now Mommy?”
Corp Fin Updates the “Financial Reporting Manual”
Coinciding with the annual AICPA Conference being held in DC right now, Corp Fin released an updated version of its Financial Reporting Manual yesterday (this Manual is formerly known as the “Accounting Training Manual”). In the past, this was updated every 5 years or so – now Corp Fin is attempting to update it quarterly. This is the third update this year. Technically, this is an internal Staff document – but the SEC makes it publicly available as a valuable informal resource.
The dozen and a half sections marked “updated 9/30” are the ones updated (even though they just came out now). Compared to what I blogged about recently, this update does not include the 25-years worth of content based on meeting with the “CAQ Regs” Committee. That is forthcoming…
Here are some notes from what happened yesterday at the AICPA conference from FEI’s “Financial Reporting Blog.”
Now Available: Fall Issue of Compensation Standards
We just dropped the Fall 2009 issue of the Compensation Standards print newsletter in the mail to subscribers. Subscribers can access it now as we have posted the issue online. It provides timely analysis of compensation action items that boards should be focused on now.
Act Now: Members of CompensationStandards.com are entitled to a free copy of this newsletter. As all memberships expire at the end of December, you should renew now (or try a no-risk trial).
