Anonymize executive compensation disclosure documents for benchmarking – CCPA/HIPAA-compliant de-identification per 17 CFR §229.402
Reg S-K §229.402 mandates detailed disclosure of named executive officer compensation in proxy statements and annual reports, linking individual names to salary, bonus, equity awards, and perquisite totals. anonym.legal pseudonymizes these named-individual pay records so compensation consultants, remuneration advisers, and peer-benchmarking teams can analyze pay structures without processing individually identified compensation data.
When this applies
Use this workflow when executive compensation schedules, tally sheets, or Reg S-K §229.402 disclosure drafts are shared with external compensation consultants, remuneration committees, or governance advisers for benchmarking where the executive's identity is not required.
How anonym.legal handles it
- Upload executive compensation schedules, pay tally sheets, or draft §229.402 disclosure tables in PDF, XLSX, or DOCX format.
- The engine identifies named executive officers across all compensation tables: Summary Compensation, Grants of Plan-Based Awards, Outstanding Equity Awards, Option Exercises, Pension Benefits, and Nonqualified Deferred Compensation.
- Each named executive is pseudonymized consistently across every compensation table in the document set.
- Pay figures, equity award values, vesting schedules, and performance metrics are retained as structural analytical content.
- Narrative CD&A sections referencing executives by name are pseudonymized at every name occurrence while preserving compensation-philosophy and benchmarking-methodology descriptions.
- The reversible mapping is stored encrypted; re-identification is available when the final proxy draft must be prepared.
- The pseudonymized output is exported for distribution to compensation consultants and committee advisers.
What you provide
- Executive compensation tally sheets and draft §229.402 tables in PDF, XLSX, or DOCX format
- CD&A narrative sections in DOCX format
- List of named executive officers to be pseudonymized
Limitations & cautions
- anonym.legal does not assess whether the compensation program satisfies say-on-pay advisory vote requirements or Reg S-K §229.402 disclosure adequacy; those determinations require compensation counsel.
- CD&A narratives that describe an executive's role or tenure in highly specific terms may retain indirect identifiability even after name pseudonymization.
- Peer-benchmarking comparisons that reference external public-company proxy data are not processed by this tool; only uploaded documents are pseudonymized.
- The tool does not calculate tally sheet figures or validate pay-disclosure arithmetic.
FAQ
Can the tool pseudonymize executives across all six Reg S-K §229.402 compensation tables simultaneously?
Yes. All six required tables are processed in a single pass with consistent pseudonym assignments, so the same executive's identity is replaced by the same placeholder in every table.
Will performance metrics and goal targets be preserved for benchmarking?
Yes. Performance metrics, EBITDA targets, TSR percentiles, and vesting conditions are structural content and are preserved in plain text. Only the names of the executives to whom those targets apply are pseudonymized.
Can this workflow be used for pay-ratio disclosure analysis under §229.402(u)?
Yes. The CEO's compensation figure used in the pay-ratio calculation is linked to the named CEO and can be pseudonymized for consultants reviewing the ratio methodology without disclosing the specific executive's identity.