SEC Proposes New Pay-for-Performance Rules

SEC Proposes New Pay-for-Performance Rules

On April 29, the Securities and Exchange Commission proposed new rules to require annual disclosure in proxy and information statements under the Securities Exchange Act of 1934 regarding the relationship between executive compensation actually paid by, and the financial performance of, registrants (excluding foreign private issuers, registered investment companies and emerging growth companies).

SEC Takes Aggressive Approach to Fortify Dodd-Frank’s Whistleblower Rules

On April 1, 2015, the Securities & Exchange Commission (the “SEC” or “Commission”) fined a public company $130,000 for requiring employees involved in internal investigations to sign a confidentiality agreement that the Commission deemed violative of the whistleblower protections contained in the Dodd-Frank Act.

SEC Whistleblowing Program: The Agency Means Business

By | The D&O Diary | April 20, 2015
Credit: MrGiles

The SEC wants you to know that it means business about its whistleblowing program.OKOn April 1, 2015, in the latest in a series of steps to protect and encourage whistleblowers, the agency entered an order in an enforcement action against KBR saying that the company’s confidentiality requirements for internal investigation witnesses violated the agency’s whistleblowing rules.

The SEC Continues to Turn Up the Heat On Private Equity

By | The D&O Diary | April 14, 2015

In the following guest post,  Elan Kandel, who is a member of the Cozen O’Connor law firm, takes a look at the SEC’s recent investigative interest in the way private equity firms disclose their fees. He also reviews the insurance issues these types of SEC investigations and enforcement actions raise.