New study gives mixed reviews to companies filing conflict minerals reports

by Cydney Posner A new study on conflict minerals compliance from Tulane University and Assent Compliance, a compliance software and services firm, revealed that about 90% of filers of conflict minerals reports indicated that they were unable to determine if their products were conflict free, the primary object of the conflict […]

Is the SEC considering reproposing mandatory proxy access rules?

by Cydney Posner The SEC has posted a new staff working paper, “Public versus Private Provision of Governance: The Case of Proxy Access,” reporting on a study conducted by the SEC’s  Division of Economic and Risk Analysis (DERA), of the “tradeoffs” between universal regulatory mandates and so-called “private ordering” in the […]

Does disclosure of a high CEO-employee pay ratio affect consumer behavior?

by Cydney Posner The answer is yes, according to a recent study from the Harvard Business School,  “Paying Up for Fair Pay: Consumers Prefer Firms with Lower CEO-to-Worker Pay Ratios.  Just in time to be part of the mood music for the SEC’s expected adoption of final pay-ratio rules on […]

SEC sets meeting to vote on final pay-ratio rules

by Cydney Posner As widely rumored, the SEC will consider  final adoption of  the Dodd-Frank pay-ratio rules on August 5.

House bill to require disclosure of efforts to eliminate slave labor from supply chains

by Cydney Posner Yesterday, Representatives Carolyn Maloney and Chris Smith introduced H.R. 3226, the ‘‘Business Supply Chain Transparency on Trafficking and Slavery Act of 2015.’’  The bill comes on the heels of articles about slavery and human trafficking like this one on the front page of the NYT, documenting the use of slave […]

SEC to adopt pay-ratio rules without broad exclusions, reports WSJ

by Cydney Posner The SEC may adopt final pay-ratio rules, mandated by Dodd-Frank, possibly as early as next week.  More significantly, according to the WSJ, the final rules will be adopted “without broad exclusions sought by companies.” The pay-ratio proposal requires most public companies to disclose the relationship of CEO pay […]

Cooley Alert: SEC Proposes Long-Awaited Compensation Clawback Rule

by Cydney Posner See our Cooley Alert on the SEC’s new rule proposal regarding recovery of erroneously awarded compensation, the so-called clawback rule.  It’s called SEC Proposes Long-Awaited Compensation Clawback Rule.