In order to comply with new NYSE and NASDAQ listing standards implemented as part of Dodd-Frank, a compensation committee of a company can only select or obtain advice from a compensation consultant (or legal counsel or other advisers) after taking into consideration six enumerated factors designed to evaluate the adviser’s independence. Outside advisers are not required to be independent, so long as the six factors were evaluated prior to the adviser being hired. However, companies are required to disclose any conflicts of interest of any compensation consultant (but not legal counsel or other advisors) who had any role in determining or recommending the amount or form of executive or director pay during the last fiscal year. The Dodd-Frank Act's regulation and disclosure of the independence of compensation consultants is an area that is substantially expanded from SEC disclosure requirements previously in effect. However, because most large companies have independent board compensation consultants, the Center does not expect the requirements to have a substantial impact on current practices.