Pay Versus Performance

By J. Marc Fosse and Ameera Salem

Seyfarth Synopsis:  As reporting companies prepare their Pay Versus Performance (PVP) disclosures for their upcoming proxy statements, they should take into consideration the most recent guidance on the topic in Securities and Exchange Commission’s (SEC’s) Compliance & Disclosure Interpretations (CD&Is).

The PVP disclosure rules (Item 402(v) of SEC Regulation S-K) require public

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