SEC Say on Pay Open Meeting Today

Further consideration will be devoted to the implementation of Section 951 of the Dodd-Frank Wall Street Reform and Consumer Protection Act  which are scheduled to apply to proxy materials prepared in connection with annual shareholder meetings taking place after January 20th 2011.say on pay rules at an open meeting of the SEC on January 25. There aren't too many hot button issues here but clarity may be provided on the exemption of smaller or new filers and some other nuances of how to deal with furture shareholder proposals.

If you get a chance there are also some interesting comments posted on sections 953 and 954 most recenting presenting positions on aspects of director independence rules (from the David Gordon of Frederic W. Cook) and the materiality of the CEO to average employee ratio  which is not scheduled for implementation for this proxy season (from Richard Trumka, President of the AFL-CIO and Kenexa Compensation client).

If you are active in M&A you may also want to keep an eye specifically on commentary regarding Proposed Rule: Shareholder Approval of Executive Compensation and Golden Parachute Compensation; File No. S7-31-10.