Title

Considerations for Drafting the 2009 Proxy Statement
Client Memorandum

Created date

1/28/2009

Executive compensation continues to dominate headlines and remains at the forefront of key governance issues. While most U.S. companies are now in their third year of implementing the SEC’s revised executive compensation disclosure requirements, companies still grapple with new developments and evolving situations related to directors and officers. Although the complexity of the disclosure rules often requires a detailed fact-based analysis in many cases, we provide below a brief summary of some practical considerations on several disclosure points. The SEC has not announced any current plans for widespread review and guidance of 2009 proxy statements.