SEC Professionals Groups

We are coming out of SRC status and need to engage a third party to calculate and provide the stock performance graph, so any recommendations are helpful. What company do you use to prepare your stock performance graph for the 10-K? or Do you prepare the graph for your company in house? Do you have legal counsel, investor relations or compensation consultants help with determining a peer group?

------------------------------
Jamie Yamamoto
Director of Financial Reporting
Silvergate Capital Corporation
------------------------------

Thanks Jamie! For the 5-year cumulative total return graph at Overstock, we used Zaks Investment Research. Our investor relations team owned the account, but provided us with the graph for our 10-Ks. Hopefully this helps!

-steve

------------------------------
Steve Soter
Executive Advisor
SEC. ESG & SOX Pro Groups
------------------------------

Original Message:
Sent: 10-25-2022 12:58 PM
From: Jamie Yamamoto
Subject: Performance Graph for the 10-K

We are coming out of SRC status and need to engage a third party to calculate and provide the stock performance graph, so any recommendations are helpful. What company do you use to prepare your stock performance graph for the 10-K? or Do you prepare the graph for your company in house? Do you have legal counsel, investor relations or compensation consultants help with determining a peer group?

------------------------------
Jamie Yamamoto
Director of Financial Reporting
Silvergate Capital Corporation
------------------------------

Thanks! This is very helpful. That name sounds familiar, so I think that's the firm I've used before.

------------------------------
Jamie Yamamoto
Director of Financial Reporting
Silvergate Capital Corporation
------------------------------

Original Message:
Sent: 11-01-2022 05:14 PM
From: Steve Soter
Subject: Performance Graph for the 10-K

Thanks Jamie! For the 5-year cumulative total return graph at Overstock, we used Zaks Investment Research. Our investor relations team owned the account, but provided us with the graph for our 10-Ks. Hopefully this helps!

-steve

------------------------------
Steve Soter
Executive Advisor
SEC. ESG & SOX Pro Groups

Original Message:
Sent: 10-25-2022 12:58 PM
From: Jamie Yamamoto
Subject: Performance Graph for the 10-K

We are coming out of SRC status and need to engage a third party to calculate and provide the stock performance graph, so any recommendations are helpful. What company do you use to prepare your stock performance graph for the 10-K? or Do you prepare the graph for your company in house? Do you have legal counsel, investor relations or compensation consultants help with determining a peer group?

------------------------------
Jamie Yamamoto
Director of Financial Reporting
Silvergate Capital Corporation
------------------------------

Hey Jamie

At Keurig Dr Pepper, our External Reporting and Technical Accounting team completes this information for the performance graph in Item 5. For a peer group, we actually use S&P Food and Beverage Select Industry Index instead of the company determining a peer group.

In other conversations, it sounds like in regards to the SEC's new ruling on pay vs. performance, an industry index may be more helpful than a company determined peer group.

Hope this helps.


------------------------------
Chris Pettit
Vice President of Accounting
Keurig Dr Pepper Inc.
------------------------------

Original Message:
Sent: 10-25-2022 12:58 PM
From: Jamie Yamamoto
Subject: Performance Graph for the 10-K

We are coming out of SRC status and need to engage a third party to calculate and provide the stock performance graph, so any recommendations are helpful. What company do you use to prepare your stock performance graph for the 10-K? or Do you prepare the graph for your company in house? Do you have legal counsel, investor relations or compensation consultants help with determining a peer group?

------------------------------
Jamie Yamamoto
Director of Financial Reporting
Silvergate Capital Corporation
------------------------------