By Cydney Posner

While republicans are reported to be planning to propose over 400 amendments to the Dodd financial reform bill, Dodd's own 114-page "Manager's Amendment" includes several points of interest that become part of the bill, including the rumored requirement to disclose internal pay equity:

  • GAO to conduct (another) study to identify and examine potential conflicts of interest that exist between the staffs of the securities underwriting and securities analyst functions within the same firm;
  • Amendments to Reg S-K 402 to require disclosure regarding internal pay equity, i.e. (A) the median of the annual total compensation of all employees of the issuer, except the CEO, (B) the annual total compensation of the CEO, and (C) the ratio of the two (with the "total" being determined by the same method as total comp in the SCT, including equity and other benefits, a calculation that should be a fun full-employment opportunity for someone, or some twenty, depending on the size of the company); and
  • Prohibition on broker discretionary voting in connection with election of a member of the board of directors of an issuer, executive compensation or any other significant matter, as determined by the SEC.

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