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Skadden Discusses New SEC Pay-Versus-Performance Compliance & Disclosure Interpretations

Reynolds Holding

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.

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Skadden Discusses SEC Guidance on Pay-Versus-Performance Disclosure

Reynolds Holding

The 15 new Compliance & Disclosure Interpretations (C&DIs) are the first published guidance from the staff on the PVP rules and cover a broad range of topics. Prior-year equity awards granted to a first-time NEO must be included in CAP adjustments. Further support comes from C&DI 128D.06, C&DI 128D.02 C&DI 128D.02

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