Executive Compensation Regulation - Comment Letter - NYSE Euronext - April 29, 2011

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Dodd-Frank Timeline, Listing Standards for Compensation Committees, SEC
Final Rule Issue Effective Date Compliance Date, Rule Changes Compliance Date, Disclosure
June 27, 2012 July 27, 2012 September 25, 2012 January 1, 2013

Listing Standards for Compensation Committees
April 29, 2011

From the comment letter:

  • "We believe the 90-day deadline in proposed rule 10C-1(a)(4)(i) should be adequate to formulate and submit proposed rules to the Commission. However, we do not believe exchanges can be under an obligation to have rules approved by the Commission within any set timeframe, because approval by the Commission or its staff acting pursuant to delegated authority is not something an exchange can control."
  • "We believe that an exchange should be authorized to provide its listed companies a transition period to come into compliance with the exchange's new rules required by rule 10C-1... Similarly, we believe that an exchange should have the flexibility to permit an issuer listing in conjunction with its initial public offering to phase-in its independent compensation committee under the exchange rules to be adopted pursuant to rule 10C-1."
  • "We believe it would be helpful for the Commission to clarify, in the adopting release or in the rule text, that the general exemptive authority exchanges would have under proposed rule 10C-1(b)(5) is not limited to 'smaller reporting issuers.'"
  • "We do not believe it would be appropriate for the Commission to specify additional factors that exchanges must consider in developing compensation committee independence standards, beyond those set forth in Section 10C."



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