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Speculation that comp data of close to 2,000 U.S. GC’s a year are disclosed in annual reports

Some publications regularly trawl the annual reports of U.S. publicly traded companies and assemble those that include the general counsel in the five most highly paid executives.  The articles they publish list the reported data in tables and inevitably headline the general counsel who “made the most last year.”  It is usually someone who cashed in a significant amount from accumulated stock options and restricted stock grants.


What I hadn’t seen is data on the number or proportion of general counsel in publicly traded companies who make enough to find themselves one of the top five.  The Conf. Bd. Rev., Summer 2011 at 45, tells us part of the answer: It cites a Towers Perrin study that “recently revealed that CFO’s, heads of legal, and HR leaders showed up among the top five highest-paid execs 76, 38, and 5 percent of the time, respectively.”  I think that means that almost four out of ten annual reports gave the general counsel’s compensation data.  If so, that would be a reasonably representative selection of data.


Given that there are something like 5,000 U.S. companies with shares traded on exchanges, every year data must be reported to the SEC and shareholders on close to 2,000 general counsel.

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