Corporate disclosure departments may be gearing up for even more work, with proposals due in the coming weeks that will require more information about how companies pay employees, among other things.

In testimony before a Senate sub-committee June 2, SEC Chairman Mary Schapiro repeated her promise for a broad package of corporate disclosure improvements aimed at giving shareholders more information about key corporate policies and practices, such as pay policies and incentive arrangements.

While exactly what the SEC will propose remains to be seen, Schapiro said the agency will unveil proposals next month that could require more disclosure of director nominee experience, an explanation of why a board chose an independent chair or combined CEO and chair structure; greater disclosure about how boards manages risks, generally and in the context of compensation, and information about compensation consultant conflicts of interests.

In particular, Corporate America has been buzzing about possible new disclosure proposals around executive pay. Schapiro told lawmakers that the Commission will consider "whether greater disclosure is needed about a company's overall compensation approach, beyond decisions with respect only to the highest paid officers."

That's led to speculation about whether the SEC will revive a 2006 proposal, dubbed the "Katie Couric rule," that was omitted from its final rule overhauling executive compensation disclosure. The provision would've required companies to disclose the total compensation and job description of their three highest-paid non-executive employees who earn more than the company's named executive officers.

"It seems to suggest that a Katie Couric-type of rule might be back on table," says Mark Borges, a principal at compensation consulting firm Compensia. However, he says that provision "doesn't get to the issue that's bothering people right now."

With the light shed on financial institutions' pay practices by the economic crisis, he says there's more focus on risky pay practices than on pay amounts.

"The momentum toward non-executive pay disclosure became a big issue when the financial crisis hit," he says. "It seems the interest now isn't so much in any individual's specific compensation as much as it is on companies' overall approach to compensating their workforce generally."

Moreover, Borges says the SEC would "face the same dilemma" it faced in proposing three provisions three years ago. "First, there was uncertainty as to whether the SEC had any jurisdictional basis to require that kind of disclosure," since proxy disclosures typically relate to the purpose of the annual meeting, and directors don't set pay below the executive level, says Borges. Second, he says, "There wasn't any constituency for it. Companies didn't want to do it and investors didn't want it."

He says the SEC may propose companies make a more general disclosure about how they compensate their workforce and the considerations that go into compensation structures, including whether they provide incentives that "encourage behavior that would potentially undermine stability of the business."

"Whatever they do would likely be aligned with a requirement for companies to say more about how they analyze and mitigate risks related to their executive pay programs," he says.

He says one possibility is a requirement akin to a provision included in legislation that passed the House in April. The Grayson-Himes Pay for Performance Act, which seeks to limit bonuses and pay for executives of bailout funded banks and financial institutions, would, among other things, require financial institutions that take TARP money to report annually how many officers, directors, and employees received or will receive total compensation over each of five specified thresholds in that fiscal year.

"They might do something like that, coupled with a requirement" for companies to disclose information about how their compensation philosophy applies to workers that make more than a certain amount, he says.

Borges also expects the SEC to propose reversing a December 2006 change to its rule that affected how companies value and disclose equity compensation.

The change, which caught companies off guard, currently requires companies to state the value of stock and option awards over the entire lifespan of the award. Initially, companies were to report the full, fair value of the award at the time the grant was made.

"The indications I've heard are that they're seriously considering going back to the original rule," says Borges. "Relatively speaking, that's a simpler approach for companies to comply with and for investors to understand. People are familiar with and comfortable with that number."

Noting that any new requirements stand to make the already lengthy disclosures related to pay even longer, Borges says, "It would be nice to see whether there's anything they can condense or shorten."