Compliance officers take note: The Securities and Exchange Commission updated their rulemaking deadline schedule last Friday, postponing its target dates on some of the Dodd-Frank Act’s rules. Of significance are the delays under Section 953 and 955, which include provisions on pay-for-performance, pay ratios, and hedging by employees and directors, as well as Section 954 regarding the executive compensation clawback provision. The deadline has been pushed back to between January and June of next year, which means companies will not see many changes in the next proxy season to the method they will need to disclose their pay practices that are not already covered under the SEC’s compensation discussion and analysis requirement.
Law firm Davis Polk & Wardwell said in a statement, “The SEC Website contains a schedule of Dodd-Frank rulemaking, which has been helpful but at times confusing when the schedule is updated with little notice … The real question is whether any of the executive compensation disclosure rules will apply to the 2012 proxy season.”
