The New Rules of Pay Versus Performance
In 2025, pay versus performance (PVP) stopped being “new” and started becoming diagnostic. The third full year of SEC-mandated disclosures under Item 402(v) of Regulation S-K gave boards, investors, and advisors something they did not...
The Hidden Costs of In-House Proxy Table Preparation: A Company’s Guide to Risk vs. Reward
In recent proxy seasons, SEC staff have issued numerous comment letters focused on executive compensation disclosures—particularly Pay Versus Performance (PvP) calculations, footnote clarity, and consistency across compensation tables—underscoring how easily errors can arise in this...
Equity Compensation Table “Gotchas”: Common Pitfalls and How to Avoid Them
At Infinite Equity, we spend a significant amount of time building Pay-Versus-Performance disclosures, and our work does not stop there. We also assist clients in preparing the other core equity compensation tables required for their...
Five Practical Improvements for Modernizing Executive Compensation Disclosure
As the SEC prepares to host its upcoming roundtable on Executive Compensation Disclosure Requirements on June 26th, it is a perfect time to reimagine how companies disclose pay practices in a way that better serves...
Reframing Compensation Actually Paid, TSRs, and the CEO Pay Ratio into the SCT
In the first installment of Infinite Equity’s Five Practical Improvements for Modernizing Executive Compensation Disclosure, we explore combining the Summary Compensation Table with the Pay versus Performance Table Disclosure, CEO Pay Ratio, and 10-K Performance...
Reframing Stock Vesting, Option Exercises, and Compensation Actually Paid into the Outstanding Equity Table
In the second installment of Infinite Equity’s Five Practical Improvements for Modernizing Executive Compensation Disclosure, we recommend streamlining three important and useful tables to get a better overview of compensation. The three independent tables in...
Revisiting the Termination & Change-In-Control Disclosure
In the third installment of Infinite Equity’s Five Practical Improvements for Modernizing Executive Compensation Disclosure, we review potential revisions to Item 402(j) of Regulation S-K: Potential payments upon termination or change-in-control. Background Item 402(j) of...
Rightsizing the Number of NEOs: Why Less is More
This position paper proposes a modernization of the SEC's executive compensation disclosure requirements by limiting the number of Named Executive Officers (NEOs) disclosed in proxy statements to three roles: Chief Executive Officer (CEO), Chief Financial...
Leveraging Modern Technologies
In the final installment of Infinite Equity’s Five Practical Improvements for Modernizing Executive Compensation Disclosure, we recommend utilizing contemporary technologies in Executive Compensation Disclosures. Infinite Equity has already proposed four significant changes to the Executive...
Pay Versus Performance Disclosures: Potential Alternatives for “Compensation Actually Paid”
On June 26th, the SEC will be hosting roundtables focusing on executive compensation disclosures. One of the anticipated discussion points will be Pay versus Performance and the definition of “Compensation Actually Paid.” We believe this...
