SEC Provides Guidance on Forthcoming Report on 2007 Executive Compensation Disclosures

October 01, 2007

In August, the SEC Staff, through a special Task Force within the Division of Corporate Finance, distributed comment letters to 350 public companies regarding their executive compensation disclosures, including the Compensation Discussion & Analysis (CD&A) and tabular disclosure required by Item 402 of Regulation S-K. These comments were previewed in a speech by John White, Director of the Division of Corporate Finance, given to the American Bar Association on August 14, and followed on the heels of updated interpretive guidance published on the SEC’s web site on August 8. The speech and interpretive guidance were discussed in a prior DechertOnPoint update (see August 2007/Special Alert).

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