With hundreds of staffers at the Securities and Exchange Commission plowing through thousands of filings, it’s too soon for the Division of Corporation Finance to broadly assess how companies are doing in complying with expanded disclosure requirements around executive compensation.

But that doesn’t mean they’re not studying the disclosures and commenting on them as they read them, said Shelley Parratt, deputy director of the division with responsibility for disclosure operations. Parratt was a keynote speaker this week at Compliance Week 2010, giving companies an earful on how the division analyzes corporate disclosures.

She focused heavily on new SEC requirements that took effect in February for companies to beef up their disclosures around compensation policies and practices that pose a material risk to the company, stock and option awards to executives and directors, and other issues related to company leadership and compensation. Now that calendar year companies have filed their 10Ks for the prior year, the staff is up to its elbows in disclosures to study.

“We’re in the time of year I call the pig in a python,” Parratt said. “We’re frantically – thoroughly, and frantically – going through disclosures. When I say it’s too soon to tell, it’s because we haven’t necessarily reached conclusions on the disclosure of a vast number of companies. That doesn’t mean we haven’t reviewed them, and it doesn’t mean we haven’t issued comments on that disclosure. But we haven’t resolved the disclosure cycle.”

Parratt said she recognizes the first cycle of reporting under new requirements is a bit like “a shot across the bow.” Companies put out their first year disclosure, then study peer disclosures, industry practices, and shareholder reaction, then adjust the next disclosure accordingly.

“What we see in the first year disclosure is often vastly different from what we see in second year disclosure,” she said. “That doesn’t mean disclosure in first year was bad, poor, inadequate, or not in compliance. It is just a normal process of accretion in disclosure.”

To comply with the new requirement, SEC staff is looking for more information on the decisions around compensation rather than the framework for making decisions, Parratt said. “Shareholders are frustrated with the length and the complexity of (compensation discussion and analysis),” she said. “When the CD&A is many pages long, focused on the process rather than the philosophy, shareholders miss what the CD&A was meant to convey.”

She reminded companies that they are required to provide some focus on performance targets if they are material. “When targets are not met, that doesn’t mean it wasn’t material,” she said. If a compensation committee decides to abandon a target and award a discretionary bonus, or if it pays no bonus at all, a material target must be disclosed if it’s an important part of management incentive, she said.

It’s also not adequate to ignore or gloss over the requirement because of competitive concerns. “It is not sufficient to say it’s a challenging goal,” Parratt said.

Be assured if the disclosure doesn’t say enough, the SEC will ask for more information, she said. “No company should wait for us to prompt it into providing the required disclosure,” she said. “With regard to any material item in the compensation disclosure, a company that waits until it receives a comment from us to comply with our disclosure requirements should be prepared to amend its filings.”