With an agenda full of congressionally mandated studies and rulemaking to tackle thanks to the Dodd-Frank Act, the Securities and Exchange Commission is trying a new approach to getting public input: inviting public comment on a number of topics even before it has proposed rules or opened official comment periods.

With the ink barely dry on the Wall Street Reform and Consumer Protection Act, the SEC has already created a series of e-mail inboxes so "anyone interested can easily weigh in" on upcoming rulemaking, Chairman Mary Schapiro noted in July 27 remarks before the Chamber of Commerce's Center for Capital Markets Competitiveness.

The mailboxes are organized by topic, starting with rules that have the shortest time frame for implementation.

Schapiro said the idea "is to offer maximum opportunity for public comment and to provide greater transparency."

She also noted that the staff will "try to meet with any interested parties who seek to meet with us," and will ask those who request meetings to provide an agenda of intended topics prior to the meeting that will be filed in the public e-mail file. Meeting participants will also be encouraged to submit written comments to the public file, and Schapiro noted that she expects to hold public hearings on selected topics.

Among other things, Schapiro noted that the SEC will be adopting a number of rules related to corporate disclosures, especially in the area of executive compensation. For instance, the law requires all public companies to hold advisory say-on-pay votes at least once every three years, as well as votes on golden parachutes that provide payments to executives in the wake of mergers, acquisitions, and major asset transactions. Companies will also be required to calculate and disclose the median total compensation of all employees and the ratio of CEO pay to that of employees, to disclose whether employees or directors are permitted to hedge against a decrease in value of options granted as part of their compensation, and to develop "clawback" policies for reclaiming incentive-based pay from current and former executive officers after a material financial restatement.

Rules governing when brokers can vote proxies without instruction from beneficial holders will also be revised so brokers can't vote on compensation matters, such as the new say-on-pay requirement, or other significant matters that the SEC determines by rule.

With confirmation of the Commission's authority to adopt rules to facilitate shareholder access to the proxy to nominate directors now official, Schapiro also said she is "committed to bringing a final rule to the Commission for consideration so that rules will generally be in effect in time for the 2011 proxy season."

She also pledged to follow up on public comments on the proxy plumbing concept release now out for comment.

"While we will be busy with regulatory reform rulemaking, we can, and will, make the time to address these critical issues," she stated.