On July 16, 2009, the Treasury Department proposed additional legislation as part of the Investor Protection Act of 2009[1] (the “Act”), titled Subtitle D – Executive Compensation (“Subtitle D”). The proposed new legislation would require all U.S. public companies to grant shareholders an annual non-binding vote on executive compensation packages (say on pay) and further regulate compensation committees. The proposals in Subtitle D represent the implementation of the Administration’s previously announced initiatives.


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