The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Mon, 03 Aug 2026 11:32:22 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.8 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png Early Results from Say on Pay – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 Early Results from Say on Pay https://corpgov.law.harvard.edu/2011/04/17/early-results-from-say-on-pay/?utm_source=rss&utm_medium=rss&utm_campaign=early-results-from-say-on-pay https://corpgov.law.harvard.edu/2011/04/17/early-results-from-say-on-pay/#comments Sun, 17 Apr 2011 11:06:52 +0000 http://blogs.law.harvard.edu/corpgov/?p=16274?d=20150120092931EST Posted by Noam Noked, co-editor, HLS Forum on Corporate Governance and Financial Regulation, on Sunday, April 17, 2011
Editor's Note:

The following post comes to us from Michael R. Littenberg, a partner at Schulte Roth & Zabel LLP, and is based on Schulte Roth & Zabel client alert by Mr. Littenberg, Farzad F. Damania and Justin M. Neidig.

Beginning on Jan. 21, 2011, most domestic public companies became subject to the SEC’s new “say on pay” and “say on frequency” rules.

In the first 30 days of the new rules, 95 companies (including TARP recipients) held SOP votes and 92 companies held SOF votes. At 93 of the 95 companies, NEO compensation was approved by shareholders, in most cases by an overwhelming percentage of the votes cast. In contrast, frequency recommendations did not receive nearly as much support:

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