Reynolds Holding

NOVEMBER 30, 2023

On November 21, 2023, the staff of the Securities and Exchange Commission’s (SEC’s) Division of Corporation Finance issued eight new Compliance & Disclosure Interpretations (C&DIs), and revised two previously issued C&DIs, relating to the final pay-versus-performance (PVP) disclosure rules adopted last year.

Compliance 40

Compliance Total Shareholder Return Dividends Market Capitalization 40

Reynolds Holding

OCTOBER 27, 2022

The Commission “acknowledge[s] that SRCs and EGCs may face disproportionate costs of compliance as compared to other companies,” but also speculates that they “may realize disproportionate benefits.” [11] Instead, the Commission is requiring companies to claw back compensation based on stock price and total shareholder return (“TSR”).

Total Shareholder Return 45

Total Shareholder Return Compliance Corporate Finance Banking 45

Reynolds Holding

MARCH 5, 2023

The staff of the Securities and Exchange Commission’s (SEC’s) Division of Corporate Finance recently issued guidance to address open questions related to the final pay-versus-performance (PVP) disclosure rules adopted in 2022. Further support comes from C&DI 128D.06,

Equity 45

Equity Dividends Total Shareholder Return Corporate Finance 45