Executive compensation disclosure remains a significant topic in corporate governance law. Since the U.S. Securities and Exchange Commission revised its executive compensation disclosure requirements last year, issuers of publicly traded securities have struggled to understand the level of disclosure necessary to adequately comply with the new regulations.

In October, based upon its assessment of the 2007 proxy statements filed by 300 large issuers, SEC staff issued its “Staff Observations in the Review of Executive Compensation Disclosure.” The staff issued its remarks regarding compliance with the new disclosure rules and made several suggestions to help issuers improve their compliance.