SOP Vote for TARP

The Securities and Exchange Commission has published its final rules which require a “say on pay” (SOP) for companies which have received financial assistance under the Troubled Asset Relief Program (TARP).

The key points are that:

  • The proxy will have to disclose that the company is providing a SOP vote
  • Whether the vote is binding or not
  • Smaller companies will not be required to provide a “Compensation Discussion & Analysis” to achieve compliance
  • Issuers will be required to make accelerated disclosures of the voting results
  • The obligation for a SOP vote remains in force for as long as any TARP obligation remains outstanding


SEC TARP SOP Final Rule >>

Proxy Disclosure Final Rules >>

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