The Corporate Governance Advisor's September/October issue features our Viewpoint, "Does the SEC's Pay Versus Performance Disclosure Provide an Effective Means to Evaluate PVP?", by Ira Kay, Mike Kesner, Linda Pappas and Ed Sim.

The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) required that companies disclose the relationship of PVP and granted the SEC wide discretion in promulgating the required disclosure. At the time, Congress acknowledged that the current disclosure rules, which included the Compensation, Discussion, and Analysis (CD&A) and Summary Compensation Table (SCT), did not provide shareholders with a sufficient understanding of the relationship of compensation and performance. While the CD&A and SCT provided better visibility to the rationale for — and components of — compensation, they did not illustrate the relationship between the pay decisions made in the reporting year with the subsequent performance of the organization.

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