• SEC Staff Issues C&DIs Interpreting New Disclosure Requirements Relating to Corporate Governance and Executive Compensation
  • February 19, 2010
  • Law Firm: Fried, Frank, Harris, Shriver & Jacobson LLP - New York Office
  • On December 16, 2009, the SEC issued significant new rules requiring enhanced disclosure of compensation and corporate governance matters by registered companies. The new requirements, which are generally effective for the 2010 proxy season, are summarized in our December 18, 2009 client memorandum “SEC Issues Final Rules Concerning Corporate Governance and Disclosure of Executive Compensation” (the “Proxy Disclosure Memo”). Because of their complexity, the staff of the SEC’s Division of Corporation Finance has already issued fourteen Compliance & Disclosure Interpretations (“C&DIs”) relating to the new disclosure requirements (five on December 22, 2009 and nine on January 20, 2010), providing guidance on the requirements and certain transition issues.