In my first UpTick (“How about never? Does never work for you?”), I questioned statements by SEC Chair White that the remaining corporate governance rulemakings under Dodd-Frank would be out by year-end. Well, the SEC has now updated its regulatory rulemaking agenda and – lo and behold – final action on the pay ratio rule is now set for October 2015 (you can find the reference here). Assuming that a final rule is adopted in that time frame (which in turn assumes, among other things, that a Republican-controlled Congress won’t do something to the relevant provisions of Dodd-Frank – or to the Act in general), the pay ratio rule will first be in effect for the 2017 proxy season.
Further, based on the regulatory agenda, we shouldn’t expect rulemaking on the three other rules comprising the “four horsemen” (namely, hedging, clawbacks, and pay for performance) until October 2015 as well.
In other words, never may just work for us. Perhaps that’s another reason to give thanks?