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Are institutions expected to re-calculate prior year compensation amounts included in the 3-year compensation “look back” section of the 2006 and 2007 annual reports?

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Are institutions expected to re-calculate prior year compensation amounts included in the 3-year compensation “look back” section of the 2006 and 2007 annual reports?

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No. Institutions do not have to recalculate the compensation information for 2004 and 2005 when preparing the 3-year “look back” section of the 2006 or 2007 annual reports. However, institutions must reflect the changes to reportable compensation and the definition of “senior officer” when developing compensation reporting information for 2006 and thereafter.

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