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Towers Watson Comment Letter to SEC Recommending Clarifications to and Simplification of Pay versus Performance Proposed Rule (PDF) (PDF)
Towers Watson 
[Opinion] July 7, 2015 14 pages. "Our comments fall into the following categories: [1] Pension Calculation Issues; [2] Equity Valuation Issues; [3] Peer Group Selection; [4] TSR Calculation and Presentation; and [5] Initial Application and Transition Rule.... [We] offer suggestions where we believe the Commission can provide more clarity, simplify its approach for easier compliance or adopt an alternative approach that we believe will be an even further improvement in the measure of compensation. 'actually paid.' " MORE >> |
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