Tag: Dodd-Frank

SEC proposes new resource extraction disclosure rules — will they face another legal challenge?

by Cydney Posner This morning, the SEC voted (with Commissioner Piwowar in dissent) to propose rules, mandated by Section 1504 of the Dodd-Frank, that would require disclosure on Form SD of certain payments made to the federal and foreign governments by resource extraction issuers in connection with commercial development of oil, […]

District Court compels SEC to provide “expedited schedule” for issuing Dodd-Frank resource extraction rule — will other rule proponents follow suit?

by Cydney Posner A U.S. District Court has handed a victory  to Oxfam America in its efforts to compel the SEC to complete rulemaking on the Dodd-Frank mandate regarding resource extraction disclosures (Section 1504). Unless appealed, the decision almost puts the SEC in the vicinity of where it was in […]

SEC proposes clawback rules

by Cydney Posner At an open meeting this morning, the SEC voted, three to two, to propose rules implementing Section 954 of Dodd-Frank, the clawback provision. Both Commissioners Gallagher and Piwowar voted against the proposal. As you may recall, Section 954 required the SEC to direct the national securities exchanges […]

SEC on the verge of proposal to implement Dodd-Frank clawback provision

by Cydney Posner The WSJ is reporting that the SEC is on the verge (July 1) of proposing clawback rules designed to implement Section 954 of Dodd-Frank, “recovery of erroneously awarded compensation.” Of course, actual implementation could still be a long way off, as the proposal would be subject to […]

With two dissents, SEC proposes pay-for-performance disclosure rules

by Cydney Posner This morning, by a three to two margin, the SEC voted to propose rules requiring companies to disclose executive pay for performance. The proposal comes five years after passage of Dodd-Frank, which imposed the obligation on the SEC.  Currently, many companies voluntarily provide information that could fit […]

Companies take clawbacks into their own hands — ouch, is it always a good thing?

by Cydney Posner As Compliance Week reports, this study from PwC showed that many companies are adopting clawbacks related to their executive compensation arrangements, even before the SEC acts to implement the Dodd-Frank clawback provisions.  The PwC study looked at 100 large public companies and found that 40% had made […]

SEC issues proposal for hedging policy disclosure; Commissioners add some drama to otherwise humdrum rule proposal

by Cydney Posner This morning, the SEC posted proposed amendments to rules to implement Section 955 of Dodd-Frank, which requires, in proxy statements for annual meetings, disclosure of whether employees or directors are permitted to hedge equity securities of the company. (Apparently, the SEC voted to issue the proposal without the […]

Rare good news from the DRC?

by Cydney Posner This month, the Enough Project issued a relatively favorable report on progress in the DRC and adjoining countries in curtailing the funding of armed groups through the trade in conflict minerals (tin, tantalum, tungsten and gold –3TG).  Happily, according to the Enough Project — one of the key proponents […]