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Frederick W. Cook & Co. Comment Letter to SEC on Pay-for-Performance Disclosure (PDF)
FW CookLink to more items from this source
June 26, 2015
8 pages. "[T]he burden imposed by the Rule varies by company with considerably more time and effort required for companies that grant stock options and/or have pension plans.... More importantly, and based on our sample study, we do not believe the disclosure (prepared according to the Rule) will accurately portray the relationship between executive compensation actually paid and the financial performance of the registrant (which was the directive of the statute)[.]"

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