Reynolds Holding

NOVEMBER 30, 2023

On November 21, 2023, the staff of the Securities and Exchange Commission’s (SEC’s) Division of Corporation Finance issued eight new Compliance & Disclosure Interpretations (C&DIs), and revised two previously issued C&DIs, relating to the final pay-versus-performance (PVP) disclosure rules adopted last year. Answer: No.

Compliance 40

Compliance Total Shareholder Return Dividends Market Capitalization 40

Harvard Corporate Governance

NOVEMBER 9, 2022

Posted by Jordan Lute, Maria Vu, Glass, Lewis & Co, on Wednesday, November 9, 2022 Editor's Note: Jordan Lute is a Research Analyst and Maria Vu is a Senior Director of Compensation Research at Glass, Lewis & Co. Summary Total vs Actually Paid. This post is based on their Glass Lewis memorandum.

Equity 220

Equity Total Shareholder Return Compliance Marketability 220

Harvard Corporate Governance

OCTOBER 9, 2023

Recent Proxy and Annual Report Developments INSIDER TRADING DISCLOSURES Environmental and Social Matters Additional Annual Report and Proxy Statement Matters In December 2022, the U.S. On August 25, 2023, two SEC compliance and disclosure interpretations (“C&DI”) were issued related to these quarterly disclosures. [1]

Total Shareholder Return 188

Total Shareholder Return Equity Compliance Marketability 188

Reynolds Holding

MARCH 1, 2023

On February 22, 2023, the New York Stock Exchange and the Nasdaq Stock Market released their respective versions of a proposed rule that implements the SEC’s clawback rule mandated by Section 954 of the Dodd-Frank Act. Financial reporting measures also include stock price and total shareholder return (TSR).

Compliance 45

Compliance Total Shareholder Return Finance Equity 45

Reynolds Holding

MARCH 5, 2023

The staff of the Securities and Exchange Commission’s (SEC’s) Division of Corporate Finance recently issued guidance to address open questions related to the final pay-versus-performance (PVP) disclosure rules adopted in 2022. Further support comes from C&DI 128D.06, It is not clear from C&DI 128D.07

Equity 45

Equity Dividends Total Shareholder Return Corporate Finance 45

Reynolds Holding

OCTOBER 27, 2022

The Commission “acknowledge[s] that SRCs and EGCs may face disproportionate costs of compliance as compared to other companies,” but also speculates that they “may realize disproportionate benefits.” [11] Instead, the Commission is requiring companies to claw back compensation based on stock price and total shareholder return (“TSR”).

Total Shareholder Return 45

Total Shareholder Return Compliance Corporate Finance Banking 45