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

Compensation “actually paid” includes certain considerations for changes in pension value, above-market or preferential earnings on non-qualified deferred compensation, and changes in the value of equity awards throughout the year. the change in value of previously granted awards that vested during the year. Measuring the Performance Element.

Equity 213

Equity Total Shareholder Return Compliance Marketability 213

Reynolds Holding

MARCH 1, 2023

Deadline for Compliance What’s next: Once published in the Federal Register, there will be a public comment period of 21 days, and then the SEC must approve both listing standards. 14 prohibits the initial or continued listing of any security of a company that is not in compliance with the clawback rule. New Section 303A.14

Compliance 45

Compliance Total Shareholder Return Finance Equity 45

Value Scope

JULY 21, 2020

How do you justify making substantial investments and fundamental changes to corporate structures and culture without empirical evidence that it will make a direct impact on shareholder value, total shareholder return, net present value, and individual rates of return? What about stock price? Sources: [1] [link].

Intangible Assets 130

Intangible Assets Beta Alpha Unlevered Beta 130

Harvard Corporate Governance

OCTOBER 9, 2023

On August 25, 2023, two SEC compliance and disclosure interpretations (“C&DI”) were issued related to these quarterly disclosures. [1] Quarterly Disclosures. However, the disclosure is not required to include the pricing terms of the trading arrangement. This disclosure may be provided in tabular or narrative form. 1] C&DI 133A.01

Total Shareholder Return 188

Total Shareholder Return Equity Compliance Marketability 188

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. 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

Equity 45

Equity Dividends Total Shareholder Return Corporate Finance 45