SEC Adopts New Executive Compensation Clawback Rules for Public Companies

On November 28, 2022, the Securities and Exchange Commission (the SEC) published final clawback rules (the Final Rules) in response to the long-standing requirement under Section 954 of the Dodd-Frank Wall Street Reform and Consumer Protection Act to increase transparency and disclosure in financial reporting; the Final Rules were adopted by the SEC on October 26, 2022, and become effective 60 days following publication, i.e., January 27, 2023. READ MORE

What Boards Should Ask Management About Compensation and ESG

Corporate boards in the United States are increasingly considering ESG performance measures in incentive plans. However, there are important questions to ask about the benefits of incorporating ESG measures into compensation, the risks of doing so, and the challenges of communicating with investors, affected employees and others about what the company is doing and why. Those questions are even more urgent today, as companies face skepticism about whether ESG can drive financial performance.  
Companies can successfully link compensation to ESG, but it requires a rigorous and methodical approach tailored to the company’s particular circumstances and strategy. Here are five questions directors should ask management, what they should look for in each answer and potential red flags in those answers. READ MORE

Next Steps for CCOs – Revising Compensation Systems and Enhancing Data Preservation Technology

Just when we thought the ethics and compliance landscape was “stable,” the Justice Department pulled the compliance profession further and announced heightened expectations for corporate compliance programs.  For prognosticators like myself it is easy to predict that next year companies will have to focus on their compensations systems and data preservation capabilities. READ MORE

Florida CFO Bans ESG Investing By Florida Deferred Compensation Plan

This week, Florida CFO Patronis directed "all participating asset managers to remove ESG investment funds as options for participants in the Deferred Compensation Plan."  In effect, Patronis has now barred investments in ESG funds by the $5.1 billion Florida Deferred Compensation Plan.

Overall, this is hardly a surprising development.  The State of Florida has been at the forefront of efforts to direct state pension funds and other sources of capital away from ESG-compliant investing and towards more "traditional" investment goals.  This latest effort is merely the most recent salvo in that ongoing campaign. READ MORE

Emerging pay transparency and its impact on total rewards

Currently, one in five American workers lives in a state where certain employers are held to pay transparency standards—a reality that means employers across the country need to consider not only how they handle discussions related to pay but also about total rewards.

Pay transparency is trending upward, as California and New York recently joined Colorado and Washington in requiring employers to post salary ranges with job descriptions. READ MORE

What is the difference between the fluctuating workweek compensation method and a Belo contract?

Many employers have employees who do not work a regular schedule of 40 hours per week. For example, they may work 25 hours one week and 50 hours the next week. For ease of administration, an employer may wish to pay such employees on a salaried basis. In these instances, an employer could consider implementing either a fluctuating workweek method or a Belo contract. Though these two plans are similar, there are some key differences to consider. READ MORE

The Latest And Greatest New Pay Transparency Laws

These days, more and more lawmakers are looking to regulate the amount of salary information employers are required to provide job applicants. On January 1, 2023, California, Rhode Island, and Washington State all had new “pay transparency” laws take effect, and New York State has a new law taking effect in September 2023, following a trail already blazed by jurisdictions like Colorado and New York City. As the regulatory landscape surrounding pay transparency continues to rapidly evolve, HR and compliance personnel have struggled to stay informed. This article offers a brief survey of the current slate of pay transparency laws affecting US employers in the New Year. READ MORE

Executive Compensation Considerations in the 2023 Reporting Season

On August 25, 2022, the SEC adopted final rules requiring public companies to disclose the relationship between the executive compensation actually paid to the company’s named executive officers (NEOs) and the company’s financial performance. The final rules implement the “Pay Versus Performance” disclosure requirements mandated by Section 953(a) of the DoddFrank Wall Street Reform and Consumer Protection Act enacted in 2010 (Dodd-Frank Act). READ MORE

FTC’s Proposed Ban on Noncompete Clauses May Have Far-Reaching Implications for Executive Compensation

The Federal Trade Commission (FTC) announced a notice of proposed rulemaking on January 5, 2023, that would ban employers from entering into or maintaining noncompete clauses with their workers. The proposal was issued in response to President Joseph Biden’s July 9, 2021 executive order and related statements calling on the FTC to ban or limit employment contract restrictive covenants that restrict workers’ freedom to change jobs. READ MORE

New Year, New State Minimum Compensation Thresholds for Restrictive Covenants

For many employers, a new year is a new opportunity to update policies, procedures, and agreements—including restrictive covenants. In addition to ensuring compliance with applicable state requirements as to timing, consideration, and restrictions, companies need to be aware of applicable compensation minimums for employees being asked to sign noncompetition and nonsolicitation agreements. With the start of the new year, many states have increased minimum compensation floors for such employees. READ MORE