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The SEC revised its disclosure guidelines for executive pay in late 2006. Since that time the regulator has been sending out letters to violator companies with insufficient disclosures, but has seen little compliance. Now the commission indicates that reviews will be tighter and there’s no room for a “Mister Nice Guy” approach. In fact, its deputy director, Shelley Parratt, threatened (in a recent speech) that companies who wait until receiving staff letters faulting material noncompliance with disclosure guidelines will face the arduous task of amending filings.


  1. According to the article, what is it that the companies are not providing the SEC in these disclosures?
  2. According to the article, what are some of the other kinds of disclosures that the SEC is thinking about for the coming year?
  3. Explain the relationship between the proxy statement and the CD&A, including the type of information contained within each.


Johnson, S. (2009). “No More Lenience on Pay Disclosure: SEC,” CFO (Retrievable online at:

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