Travis Triano

On February 10, 2023, the SEC Staff issued a set of Compliance & Disclosure Interpretations (C&DIs) regarding the “pay versus performance” (PvP) disclosure rule, which covers a variet...

Davis Polk partners Kyoko Takahashi Lin and Travis Triano authored “Preparing for pay versus performance disclosure” in Practical Law. The article discusses the “pay versus performa...

We invite you to watch a Davis Polk webinar on the SEC’s new pay versus performance rule. Now that companies have started putting pen to paper on the required pay versus performance dis...

The SEC adopted the final “clawback rule” mandated by the Dodd-Frank Act requiring public companies to establish and enforce policies to recover excess incentive compensation from exe...

The SEC adopted the final rule implementing the “pay versus performance” disclosure requirement mandated by the Dodd-Frank Act, which is broader in scope than the 2015 proposed rule a...

On June 8, 2022, the SEC requested comments for the third time on its proposed clawback rule, which is required to be promulgated under the Dodd-Frank Act. As part of this reopening, the ...

The SEC proposes disclosure of additional metrics beyond total shareholder return (TSR) for this unfinished Dodd-Frank rulemaking.

The SEC’s proposals include cooling-off periods for Rule 10b5-1 trading plans, public disclosure around Rule 10b5-1 trading plans, significant new disclosures for option grants and stoc...

The SEC’s renewed request for comments on its clawback rule suggests an aggressive approach to recovery of incentive-based compensation.

The NYSE has adopted new, temporary exceptions to its shareholder approval rules in light of corporate financing needs related to the coronavirus (COVID-19) pandemic. The new rule provide...