Here's a gift from the Securities and Exchange Commission to compliance officers and executive compensation committees to usher in the new year:

The SEC recently updated its schedule for Dodd-Frank Act rulemaking for the year, and it has pushed back the deadline to propose and implement some of the rules on executive compensation, including the disclosure of pay-for-performance, pay ratios, the compensation clawback provision, and hedging activities by employees and directors.

The original deadline set by the SEC to propose these rules was between April and July 2011 while the adoption of the final rules was targeted to occur in the second half of the year. On July 29 last year, the Commission pushed back the proposal date to the second half of last year and was expecting to adopt the final rules in the first half of the year.

For some companies, however, the postponement brings little cheer. They'd rather have the certainty of the rules in place so they can begin planning for complying with them, especially for the Dodd-Frank provisions that are still fairly nebulous.

Compensation experts have cumulatively expressed their skepticism over the Commission's ability to meet the tight deadlines it had set for 2011. Of concern to them is the rule that will require companies to disclose the pay ratios of executives and employees as prescribed under Section 953 and 955. Many companies, compensation consultants, and others say the requirement to disclose chief executive officer pay as a ratio of total employee pay leaves much still to be settled. In order to meet the requirement, companies will need to gather wage information from all employees—a task that can be overwhelming for those companies with a global presence.

Attached below are excerpts of the new corporate governance and disclosure rulemaking timeline published by the SEC for 2012.  

January – June 2012 (planned)

§951: Adopt rules regarding disclosure by institutional investment managers of votes on executive compensation

§952: Adopt exchange listing standards regarding compensation committee independence and factors affecting compensation adviser independence; adopt disclosure rules regarding compensation consultant conflicts

§§953 & 955: Propose rules regarding disclosure of pay-for-performance, pay ratios, and hedging by employees and directors

§954: Propose rules regarding recovery of executive compensation

July – December 2012 (planned)

§§953 & 955: Adopt rules regarding disclosure of pay-for-performance, pay ratios, and hedging by employees and directors

§954: Adopt rules regarding recovery of executive compensation

§956: Adopt rules (jointly with others) regarding disclosure of, and prohibitions of certain executive compensation structures and arrangements for financial institutions

§952: Report to Congress on study and review of the use of compensation consultants and the effects of such use