From the Archive

Coinciding with Harvey Pitt’s inaugural CW column last week on executive pay, compensation firm Equilar conducted an analysis of performance metrics used to determine annual bonuses at S&P 100 companies. Among the top findings: Earnings per share and revenue were the top metrics used in determining CEO bonuses for 2002. According to Equilar, approximately two-thirds […]

Below is the actual text from the guidelines articulating the seven components of an effective compliance program:   Document: 2001 Federal Sentencing Guideline Manual   Chapter: §8A1.2.Application Instructions – Organizations   Section: Commentary: Application Notes: 3(k)   Click Here to View the Actual Document – Scroll Down to “Commentary” Section 3(k) (k) An “effective program to prevent and detect […]

Brief, five=page executive summary of the Ad Hoc Advisory Group’s recommended changes to the organizational sentencing guidelines.

The events of the past few weeks are a harbinger of the intense scrutiny of executive compensation that can be expected. When various members of the NYSE Board indicated their “surprise” at the magnitude of Dick Grasso’s compensation, it was a timely reminder to public companies to revisit their compensation policies and procedures. Here are […]

Download the text of the proposed amendment to the federal sentencing guidelines that pertain to effective compliance programs.

Download the complete 141-page report from the Ad Hoc Advisory Group that recommended changes to the federal sentencing guidelines.

Survey conducted by Harris Interactive claims 80 percent of investors “want the right to offer investor-nominated board candidates through the proxy ballot.”

TOP FIVE Top five compensation policy changes in 2002/2003: 23% Altered long-term incen-tive plan (LTIP) structure 11% Modified metrics for long-term/short-term incentives 9% Introduced exec. stock ownership requirements 6% Created holding period after exercising options 6% Granted exec(s) special one-time retention award View “Trends in Compen-sation Policies & Practices” SOURCE: Equilar An analysis of compensation […]

OThe GC of a subsidiary is being asked to give a back-up 302 certification to the parent company. Won’t that blow the attorney-client privilege between the GC and the sub? And is it common for a GC to provide back-up to a certification required by the principal executive and principal financial officer? What are the […]

To improve corporate behavior and to reward corporate performance we need to improve the quality and utility of the information that all corporations disclose to investors.  Our existing disclosure framework is not adequate. ABOUT THE SPEAKER Peter R. Fisher was sworn in on August 9, 2001 as Under Secretary of the U.S. Treasury for Domestic […]