The SEC announced on January 27, a reopening of the comment period for the pay-vs-performance rules that were first proposed by the SEC in 2015 as a result of the Dodd-Frank Act.  The proposed rules would add a new subsection to Item 402 of Regulation S-K, requiring registrants to describe in both a tabular and narrative format how the executive compensation actually paid by the registrant to (i) its Principal Executive Officer and (ii) the average of its other NEOs related to the financial performance (based on cumulative total shareholder return, or TSR) of the registrant over the five-year time horizon of the disclosure.  Registrants would also be required to provide information demonstrating the relationship between the registrant’s TSR and the TSR of a peer group.  In addition to reopening the comment period, the SEC is considering whether registrants should also be required to disclose pre-tax net income, net income, and another measure chosen by the registrant as additional measures of financial performance, or other performance measures used by the registrant when linking executive compensation to company performance.  The public comment period will remain open for 30 days following publication of the release in the Federal Register.