For the first time in nearly twenty years, the SEC is considering on a holistic basis whether the current executive compensation disclosure rules serve their core function of efficiently providing investors with material information on which to make voting and investment decisions.
On June 26, 2025, the SEC hosted a roundtable on executive compensation disclosure featuring various stakeholders, including advisors, investors, and directors, and their discussion touched on a wide range of topics. In advance of the roundtable, the SEC requested comments from members of the public, including as to the current requirements on perquisite disclosure and whether such disclosure affects board decision-making.
Our partners Jennifer Broder and Peter Chan were pleased to submit a comment letter discussing suggested ways to modernize perquisite disclosure given the modern realities facing CEOs and the distortions created by the existing rules.
You can read their comment letter here.