SEC Receives Thoughtful Comments on Possible Executive Pay Rulemaking

Yesterday, Liz Dunshee blogged over on CompensationStandards.com about the comments that the SEC has received so far in response to its June roundtable on executive pay disclosures. As noted in this statement from SEC Chair Paul Atkins, the SEC wanted input from the public “to ensure that the SEC’s pay rules continue to be cost-effective and result in disclosure of material information without an overload of immaterial information.” The public was invited to submit comments in advance of the roundtable, but comments continue to arrive – and these are the comments received so far.

There are two form comment letters, one of which has been sent in over 1000x. Otherwise, there are 60 distinct comment letters – including these notable ones:

1. CII
2. NAM
3. Center on Executive Compensation
4. Norges Bank
5. Chamber of Commerce
6. AFSCME
7. NYSE Institute
8. Hermes

Here are some from compensation consultants or related providers:

1. Equity Methods
2. Infinite Equity
3. Meridian Compensation Partners
4. Farient Advisors

Here are some from companies:

1. Johnson & Johnson
2. International Bancshares
3. Travelers

And here are some from law firms:

1. Cooley
2. Allen Overy Shearman
3. Jones Day
4. Davis Polk
5. Baker McKenzie
6. Cravath