Davis Polk Submits Two Comment Letters
to the SEC on Key Executive Compensation
and Corporate Governance Rulemaking

November 17, 2010

Yesterday we submitted two comment letters to the SEC on key executive compensation and corporate governance rulemaking that will have a significant impact on US public companies. 

Click here for a copy of the letter in which we address important provisions in the Dodd-Frank Act that the SEC will soon consider for proposed rulemaking, including the independence of compensation committees, pay for performance and CEO pay equity disclosure, and the adoption of recoupment policies. 

Click here for a copy of the letter in which we ask that the SEC consider, and make several recommendations related to, the proposed rules requiring advisory votes on executive compensation that effects the 2011 proxy season. 


If you have questions regarding the letters, please contact any of the lawyers listed below or your regular Davis Polk contact.

David L. Caplan212 450
Ning Chiu 212 450 4908
Edmond T. FitzGerald212 450
Kyoko Takahashi Lin212 450
Phillip R. Mills212 450
Barbara Nims212 450
Richard J. Sandler212 450
Cynthia Akard650 752


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