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As a truly independent compensation consultant, I couldn't agree with you more.

Thanks for the article.

The definition of "independent" can be difficult, but it is made more troublesome by the lobbying of large consulting firms who realize the compensation is often the "foot in the door."

Dan, I agree that getting on the compensation committee is a good way of getting your foot in the door. Too often, though, getting a foot in the door leads to getting into bed, which can be problematic when it comes to independence and objectivity.

Thanks, Stephanie; that is important news to share. And I love your bedroom analogy!

Failure to specify detailed requirements is consistent with IRS reasonable compensation and intermediate sanctions regulations. IRS likewise leaves the onus on the board of directors, probably so they can more easily hold THEM accountable rather than have to pursue the slippery outsiders.

Dan's cogent point also applies to salary surveys. We find that many consultants consider surveys by competing consulting firms to be a similar attempt at "poaching", as if employers "belong to" one consulting firm and engaging others is a forbidden intrusion or a discouraged trespass on a reservation. (We just do surveys and do no consulting, nor do we charge extra to consultants who buy our surveys, so it's not an issue for us, because our business model precludes selling consulting time.)

A forthcoming "outing" of insider exec comp consulting abuses should raise the heat for such more compelling demands for true independence. Stories should surface soon that will make some new headlines and attract additional political regulatory attention.

Oh, that picture! No one who reads this will ever be able to take the SEC seriously again...

I love how everyone gets to define their own definition of 'independent.' I really do, it's this sort of fuzzy thinking that creates high-paying jobs out of thin air.

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