SEC second comment letter on proposed pay versus performance rules, May 2022.
Pay Ratio: Other Statistical Methods, presented at the Connecticut/Boston NASPP regional conference in July 2014. This presentation shares a proposed simulation approach as an alternative to statistical sampling. The approach leverages Monte Carlo simulation to fill any gaps in data that might not be available.
SEC comment letter on the proposed pay ratio rules, December 2013. Suggests (1) that the SEC postpone implementation of Section 953(b) of Dodd-Frank until it can demonstrate how the rule is consistent with its mission and the costs are fully quantified, (2) that any rule should focus on reducing the costs of compliance by allowing for estimation techniques that favor practicality over spurious precision, (3) a proposed simulation approach to estimate median pay and (4) that distortions be eliminated by adjusting part-time and seasonal employee data.Risks and Returns of Relative Total Shareholder Return Plans, published in the WorldatWork Journal, 3rd Quarter 2013. This article demonstrates that broad market returns could impact the payout of incentive plans that pay based on how a company's total shareholder return (TSR) ranks relative to peer companies. This could result in unjustly rewarding or penalizing executives for market returns. The article suggests ways to adjust shareholder returns to evaluate only the unsystematic portion of each companies' return.
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