The SEC recently published its comprehensive review over the disclosure of 350 public companies for compliance with the new rules on executive compensation. Every company received a comment letter, which will be published along with the company’s response on the SEC’s EDGAR system within 45 days after the SEC completes its review.

So, what did the SEC find in its reviews? Well, the SEC commented that very few companies have disclosed details regarding their performance-based compensation, specifically their performance targets. These comments on performance targets by far surpassed comments in any other areas. In fact, only 45 of the top 100 companies disclosed the required specific targets. As well, many companies disclosed that they hired compensation committees but failed to tell investors how these committees analyzed executive compensation to determine appropriate amounts.

The SEC does not expect to make any additional rules in 2007 as they continue to review the effectiveness of this first major proxy season.