Final rules to implement mandatory say-on-pay votes for all public companies have arrived, with some important changes companies ought to take into account, including a two-year delay for smaller reporting companies.
In a three to two vote at a Jan. 25 open meeting, the Securities and Exchange Commission adopted rules to implement Section 951 of the Dodd-Frank Act, which requires advisory shareholder votes to approve executive compensation, votes on the frequency of SOP votes, and enhanced disclosure of and votes to approve golden parachute agreements in connection with merger transactions.

