As previously reported in Proskauer’s client alert (available here), on May 19, 2026, the Securities and Exchange Commission (SEC) proposed significant amendments to its public company reporting framework to simplify the existing filer status regime and substantially expand eligibility for scaled disclosure accommodations. Consistent with SEC Chairman Paul Atkins’ plan to “Make IPOs Great
Colleen Hart
Colleen Hart is a partner in the Tax Department and a member of the Employee Benefits & Executive Compensation Group.
Colleen advises companies, executives and boards on complex executive compensation matters. She offers a multidisciplinary approach to compensation and benefits issues with a focus on tax planning, securities laws and corporate governance. Matters she handles include the negotiation, structuring and implementation of employment and change-in-control agreements and deferred compensation, equity and incentive compensation plans. She advises on golden parachute and deduction limitation rules, securities reporting, registration and disclosure requirements and California employment laws. In addition, Colleen has extensive experience advising clients on compensation and benefits issues arising in mergers and acquisitions, initial public offerings, bankruptcies and finance transactions.
Colleen is a contributing author of The 409A Handbook (BNA 2016) and lectures frequently on executive compensation matters. As a U.S. Navy veteran, Colleen devotes a substantial amount of time to organizations that provide legal and support services to U.S. veterans.
California’s New Restrictions on “Stay-or-Pay” Provisions Require Employers to Review Repayment Agreements
A new law that took effect on January 1st, California Assembly Bill 692 (“AB 692”), significantly limits employers’ ability to require repayment of bonus, training, relocation and other retention-linked incentives upon a worker’s termination of employment. Employers with workers located in California should review and update their forms of offer letters, employment agreements…
IRS Creates Standardized Form for Section 83(b) Elections
Earlier this month, the Internal Revenue Service (“IRS”) released Form 15620, which is an approved IRS form for making Internal Revenue Code (“Code”) Section 83(b) elections. By way of background, Code Section 83(b) provides taxpayers with the ability to include the fair market value of nonvested property over the amount (if any) paid for…
ISS Issues October 2024 Update to its Executive Compensation Policies FAQs
In October, Institutional Shareholder Services (“ISS”) released an off-cycle update to its Executive Compensation Policies Frequently Asked Questions (the “FAQs”), which are available at this link: US-Compensation-Policies-FAQ.pdf (the new questions are highlighted in yellow). As described in more detail below, the updates to the FAQs address ISS’s criteria for recognizing “robust” clawback policies and realizable…