Common Questions: Navigating the SEC's New Compensation Rules

On January 19, 2007, the New York office authored an Alert Memorandum entitled, “Common Questions: Navigating the SEC’s New Compensation Rules.” Not surprisingly, the SEC’s new compensation rules have raised a number of questions. Members of the SEC staff have spoken at several programs, and we understand that the staff may issue additional written guidance, but the timing is uncertain. With companies now focused on preparing the 2007 proxy statement, we thought it would be useful to share a compilation of common questions we have addressed in this alert memorandum.