On November 29th, the SEC’s Office of the Chief Accountant and the Division of Corporation Finance published Staff Accounting Bulletin (SAB) No. 120, an interpretive guidance for public companies which details how to properly identify and disclose compensation costs for “spring-loaded awards” made to executives. Spring-loaded awards are share-based compensation arrangements in which a company grants stock options or other awards shortly before it announces market-moving information, for example, the disclosure of a substantial transaction or an earnings release that surpasses expected results.
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