CLIENT NEWSFLASH

Davis Polk Submits Two Comment Letters
to the SEC on Key Executive Compensation
and Corporate Governance Rulemaking

November 17, 2010

Yesterday we submitted two comment letters to the SEC on key executive compensation and corporate governance rulemaking that will have a significant impact on US public companies. 

Click here for a copy of the letter in which we address important provisions in the Dodd-Frank Act that the SEC will soon consider for proposed rulemaking, including the independence of compensation committees, pay for performance and CEO pay equity disclosure, and the adoption of recoupment policies. 

Click here for a copy of the letter in which we ask that the SEC consider, and make several recommendations related to, the proposed rules requiring advisory votes on executive compensation that effects the 2011 proxy season. 

 

If you have questions regarding the letters, please contact any of the lawyers listed below or your regular Davis Polk contact.

David L. Caplan212 450 4156david.caplan@davispolk.com
Ning Chiu 212 450 4908 ning.chiu@davispolk.com
Edmond T. FitzGerald212 450 4644edmond.fitzgerald@davispolk.com
Kyoko Takahashi Lin212 450 4706kyoko.lin@davispolk.com
Phillip R. Mills212 450 4618phillip.mills@davispolk.com
Barbara Nims212 450 4591barbara.nims@davispolk.com
Richard J. Sandler212 450 4224richard.sandler@davispolk.com
Cynthia Akard650 752 2045cynthia.akard@davispolk.com

 

Notice: This is a summary that we believe may be of interest to you for general information. It is not a full analysis of the matters presented and should not be relied upon as legal advice. If you would rather not receive these memoranda, please respond to this email and indicate that you would like to be removed from our distribution list. If you have any questions about the matters covered in this publication, the names and office locations of all of our partners appear on our website, davispolk.com.
© 2010 Davis Polk & Wardwell LLP