As many had predicted, the U.S. Securities and Exchange Commission will meet July 1 to consider proposed rules implementing the Dodd-Frank clawback requirement.
Although a positive first, the proposed implementation of the Dodd-Frank pay for performance disclosure is highly problematic by requiring the comparison of equity vesting over multiple years to one year total shareholder return.
In 2012, 130 S&P 500 companies received a year-over-year change in SOP support of over 10 percentage points. In 2013, there were 107 companies. In 2014, there were 90.
According to Center Research, in 2014, not a single S&P 500 company with CEO Pay Summary Compensation Table Total Pay under $10M failed to receive majority say on pay support.