Title

Inadequate Perk Disclosure Remains in SEC’s Sights
Client Memorandum

Created date

6/8/2020

A $900,000 fine is a reminder for companies to use care in tracking and disclosing all elements of executive compensation.

Executive perks may not be material to a company's financial condition. But the latest in a series of SEC cases shows that the expense, distraction, and potential reputational impact of an enforcement investigation can be significant.