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

Continue Reading Securities and Exchange Commission Pay Versus Performance Updates

By Pamela Q. Devata, Esther Slater McDonald, John Drury, and Connor M. Bateman

Seyfarth Synopsis: As part of an evolving trend of narrowly interpreting the FCRA’s “standalone” disclosure and “clear and conspicuous” disclosure requirements, the Ninth Circuit has held that users of consumer reports may violate the FCRA and ICRAA by including “extraneous” state law notices and
Continue Reading The Ninth Circuit Demands Simplicity: Background Check Disclosure Forms That Contain State-Law Notices or Improper Grammar Violate the FCRA