John White, Eric Hilfers, Jon Katz, Elad Roisman, Michael Arnold and Matthew Bobby Author Article on New Pay Versus Performance Disclosure Rule for Harvard Law School Forum on Corporate Governance

On October 28, 2022, the Harvard Law School Forum on Corporate Governance published an article written by Cravath partners John W. White, Eric W. Hilfers, Jonathan J. Katz, Elad Roisman, Michael L. Arnold and Matthew J. Bobby entitled “SEC’s New Pay Versus Performance Disclosure Rule: Important Things To Know.” Originally published for Cravath’s clients on September 6, 2022, the article summarizes the background and key features of the SEC’s recently adopted rule to implement the “pay versus performance” disclosure requirements of the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010. The article also describes the background and substance of the rule, including newly required compensation calculations, and recommends companies begin working with advisors promptly to prepare for this disclosure.

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