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...
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...