* I remain skeptical of Cox’s goal to serve up an CD&A that is useful for ‘ordinary investors’ (it reminds me of him trying to spin XBRL as saving average Joe’s time). Do individuals really want/need to read CD&A? If we can’t get fund managers to read them….

* As I’ve noted before there are some impossible aspirations here. On fancy words strung together, sometimes these are precise financial terms. Like the Cosi example a couple weeks back: the SEC asked for specifics, and some companies are replying with specific financial metrics - a lack of financial literacy is not our excuse to lament the complexity. Sometimes, complexity is the price of precision.

* Anecdotally, I would suggest in regard to executive bonus plans, two very gradual shifts including (i) discretion plays a more prominent role, and (ii) increased use of bonus pool participation; e.g., exec shares in x% of EVA created. In such a case, plan may not really have targets. So, in some cases, a component of the plan is “knowledgeable insiders sit around a table and talk turkey”…i.e., it can be hard to give the SEC what is seems to want. I believe the key here is NOT disclosure of mechanics but rather disclosure of PAY PROCESS (we don’t care about pay levels, we care about process).

But just caveats, more CD&A is better…

David Harper
bionicturtle.com