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SEC Adopts Long-Anticipated Pay Versus Performance Disclosure Rules (PDF)
Wilmer Hale 
[Guidance Overview] Aug. 29, 2022 "The adopted rules add a new tabular disclosure requirement to S-K Item 402(v) ... The method of calculating the amount of compensation 'actually paid' has been significantly changed from the original rule proposal, with several new and technical provisions ... [C]ompanies must also provide a 'clear description,' which may be presented graphically, narratively, or through a combination of both, that compares pay versus performance." |
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