Comments on the SEC's June 26th Roundtable on Executive Compensation

Identifying problems with the current rules and proposing reforms

In his remarks to the SEC’s June 26, 2025, roundtable on executive compensation disclosures, Chairman Paul Atkins encouraged members of the public to submit commentary on problems with the current disclosure regime and possible reforms.

I submitted the following in response:

In my view, the current executive compensation disclosure regime has evolved into an unwieldy system that fails to serve the fundamental purpose of securities regulation: providing clear, decision-useful information to the reasonable investor. Despite decades of regulatory additions intended to enhance transparency and accountability, these rules have instead created a complex web of disclosures that obscure rather than illuminate the relationship between executive pay and company performance.