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

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
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Skadden Discusses SEC Guidance on Pay-Versus-Performance Disclosure

Reynolds Holding

MARCH 5, 2023

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. Examples of assumptions that might have changed include the risk-free interest rate, dividend yield, expected volatility, remaining award term and the company’s stock price.

Equity 45
Equity Dividends Total Shareholder Return Corporate Finance 45
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