In general, say-on-pay frequency votes last took place in 2011 – as you may recall, with the exception of smaller reporting companies (which generally are subject to more relaxed disclosure requirements), the initial rules became effective for an issuer’s first annual meeting occurring on or after January 21, 2011. Since Rule 14a-21(b) requires a say-on-pay frequency vote every six years, many of our public company clients will have to include a frequency vote in their 2017 proxy statement (for smaller reporting companies, the date is pushed out until the 2019 proxy season).