In January 2011, the SEC pushed back the schedule for rulemaking to implement four provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The SEC now plans to issue proposed rules by August December 2011, rather than April July 2011 as originally announced, for the following:

  • §953 – Rules regarding disclosure of pay-for-performance;  
  • 954 – Rules regarding disclosure of ratio of CEO pay to average employee pay;  
  • §954 – Rules regarding policies on the clawback of compensation of current and former officers upon an accounting restatement; and  
  • §955 – Rules regarding policies on the ability of directors and employees to enter into hedging transactions.  

More information on the Commission’s Dodd-Frank rulemaking to date and its proposed schedule for future Dodd-Frank rulemaking can be found at: