With the Securities and Exchange Commission poised to approve new proxy disclosures any day now and increased scrutiny by SEC staff looming, companies should prepare to do more than the usual topside tweaking of their Compensation Discussion & Analysis for 2010.

Of course, the SEC would always say corporations should take the CD&A seriously and start afresh every year. For 2010, however, the Commission means it: Bloated executive pay has received extensive criticism for its role in causing the financial crisis, and the SEC is just one of numerous federal agencies that now want companies to disclose the logic behind their ...