Comment Section for SEC Comment Letters on Implementation of Pay versus Performance Disclosure - Compensation Advisory Partners

This webpage from Compensation Advisory Partners reports on feedback from the Securities and Exchange Commission (SEC) regarding the implementation of Pay versus Performance disclosure under Section 402 of Regulation S-K. The SEC has issued 16 comment letters to companies, primarily identifying issues with compliance to the new disclosure requirements. Common issues include missing required components of the disclosure, using multiple Company-Selected Measures, failing to reconcile non-GAAP measures against GAAP financial statements, and misinterpretation of regulations. The page also provides a detailed table summarizing the areas where each of the 16 companies received comments from the SEC. The firms include Berkshire Hathaway Inc., Expeditors International of Washington, Inc., and Xylem Inc., among others.