Commentary on the Latest Compliance & Disclosure Interpretations (“C&DIs”) from November 2023
For Thanksgiving this year, the SEC served up 10 new Compliance & Disclosure Interpretations (“C&DIs”) related to the Pay Versus Performance rules on November 21st. The 10 new C&DIs consist of revisions to 2 prior interpretations (revising 128D.7 and 128.D.18), along with 8 new Questions (128D.23 – 128D.30). Most of the new C&DIs focus on…
SEC Pay vs. Performance Rules: Preparing for Year 2 Compliance
Year 1 of filings related to the SEC’s Pay versus Performance disclosure is largely completed and it is already time to begin planning for Year 2. For most companies the biggest pain point is calculating “Compensation Actually Paid”, as the amount of data is significant. Luckily, the Year 2 process will be much easier, since only…
The SEC Pay versus Performance Rules: Market-Cap Weighted Peer TSR Calculations
The SEC announced the adoption of its new pay versus performance rules, or Item 402(v) on August 25, 2022. A detailed summary of the new rules can be found within our Alert found here. However, the intent of this shorter brief is to summarize the requirements surrounding the selection of peers and the approach used…
How to Calculate Volatility Using VWAP Price
VWAP Volatility Infinite Equity’s new approach to calculating historical volatility is to use Volume Weighted Average Prices (VWAPs). The merits of using this approach can be found in our Research Brief, A New Way to Estimate Volatility. The intent of this addendum is to illustrate how to calculate volatility using VWAP prices. Before we get…
Is VWAP Volatility a Better Method for Me?
VWAP Volatility Infinite Equity is introducing new innovative thought leadership on the development of historical volatility for purposes of ASC718. We introduced the financial theory in the Research Brief, A New Way to Estimate Volatility, and published collectively at www.VWAPVolatility.com. The intent of this article is to help the reader understand historical volatility and the…
Stop the Games
As the pandemic rages on, many people are stuck inside with limited places to go and are searching for creative ways to occupy their time outside of the occasional trip to the grocery store. This new reality has led to a heavy increase in day trading due to the availability of free trading apps, such…