New SEC Disclosure Rules 402(a)(3)

[Guest Mel Kiper Jr.]

If a company changes PFOs in the year, but both PFOs continue to work and the PFO not serving as a PFO at the end of year is one of the three most highly compensated executive officers, how may people go in the table?

PFO1 (the one not serving at the end of the year as PFO, but who still works as an executive officer) is picked under 402(a)(3)(ii) and 402(a)(3)(iii). So do I put in the PEO, PFO2 (one serving at end of year), PFO1 and three other executive officers or PEO, PFO2, PFO1 and 2 other executive officers?

[WDIK]

So do I put in the PEO, PFO2 (one serving at end of year), PFO1 and three other executive officers or PEO, PFO2, PFO1 and 2 other executive officers?

For what it's worth, my reading of the guidelines corresponds with the second option you present, but I'd much rather get your opinion on who the Falcons will take with their third round pick in the next draft.

[Steelerfan]

I agree with WDIK. See PLR 19991032