Readability of CD&As Filed Under the New Proxy Disclosure Rules

This PULSE Study looks at the readability of Compensation Discussion and Analysis sections (CD&As) filed under the new proxy disclosure rules for selected large, mid and small cap companies. This PULSE Study also includes readability scores for documents for comparison purposes, including Warren Buffet's 2007 Letter to Shareholders, The Declaration of Independence, the U.S. Constitution and Dr. Seuss's Green Eggs and Ham. Overall, none of the CD&As analyzed met the readability targets discussed by SEC Chairman Christopher Cox in his March 23, 2007 speech (but then, neither did the proxy rules as our analysis shows).