Compliance, Dividends and Total Shareholder Return

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Skadden Discusses New SEC Pay-Versus-Performance Compliance & Disclosure Interpretations

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. Answer: No.

Compliance

Compliance Total Shareholder Return Dividends Market Capitalization

Skadden Discusses SEC Guidance on Pay-Versus-Performance Disclosure

Reynolds Holding

MARCH 5, 2023

The 15 new Compliance & Disclosure Interpretations (C&DIs) are the first published guidance from the staff on the PVP rules and cover a broad range of topics. Examples of assumptions that might have changed include the risk-free interest rate, dividend yield, expected volatility, remaining award term and the company’s stock price.

Equity

Equity Dividends Total Shareholder Return Corporate Finance

Business Valuation Zone

Skadden Discusses New SEC Pay-Versus-Performance Compliance & Disclosure Interpretations

Skadden Discusses SEC Guidance on Pay-Versus-Performance Disclosure

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