News Releases

SEC Proposes "Pay Versus Performance" Disclosure Rules


WASHINGTON, May 4, 2015 - Baker Botts L.L.P., a leading international business law firm, today released a report on the U.S. Securities and Exchange Commissions proposed "Pay Versus Performance" Disclosure Rules.

The proposed rules would amend Section 953(a) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) and would require public companies to disclose information about the relationship between their executive compensation and their financial performance.

“These changes, when enacted, will add to the tool belt of activist shareholders looking to question management teams,” said Michael Gold, a corporate partner with Baker Botts based in Washington D.C.

The proposed rules would implement these provisions by adding a new Item 402(v) to Regulation S-K. The Baker Botts report and link to the proposal is available here.

Comments to the proposed rules are due 60 days after the publication of the proposal in the Federal Register although it is unclear whether the final rules will be adopted and effective prior to the 2016 proxy season.


Baker Botts is an international law firm of approximately 700 lawyers practicing throughout a network of 12 offices around the globe. Based on our experience and knowledge of our clients' industries, we are recognized as a leading firm in the energy, technology, and life sciences sectors. Since 1840, we have provided creative and effective legal solutions for our clients while demonstrating an unrelenting commitment to excellence. For more information, please visit