Devoted to Corporate Attorneys, Corporate Lawyers, and Corporate Counsel

The following is not to be considered legal advice, and is provided for information only.

The Securities Exchange Commission (SEC) issued an amendment of its Executive Compensation Disclosure Rules (adopted in July 2006).  The SEC has made these interim final rules effective with the 2007 proxy season requiring companies use these rules to determine their most highly paid executive officers for disclosure in the 2007 proxy of the compensation of "Named Executive Officers."

The dollar values required to be reported in the Stock Awards and Option Awards columns of the Summary Compensation Table and the Director Compensation Table are revised to disclose the compensation cost of those awards, without reflecting forfeitures, over the requisite service period, as described in FAS 123R. The cost is to be divided and reported in annual installments rather than in a lump sum in the year of the award. Forfeitures are required to be described in accompanying footnotes.