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Beginning in 2014, compensation committee members will face enhanced independence requirements under new governance listing standards for the New York Stock Exchange and Nasdaq (as well as other national exchanges). The new listing standards, recently approved by the Securities and Exchange Commission, will be in place as soon as January 15, 2014, or as late as October 31, 2014, depending on when a company holds its 2014 annual meeting of shareholders. While these implementation dates may seem far off today, companies and their counsel would be well advised to begin considering the impact the new standards may have on their committees and processes.

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