Are club memberships a perk?

For purposes of the proxy statement filed with the SEC, are club memberships a perk?

It’s a perk if its personal.

This is the kind of situation where if an executive fully reimburses a company that paid the executive’s dues upfront – if there is full reimbursement, there doesn’t need to be any disclosure of this as a perk. The SEC staff has a written interpretation about this

If it’s a partial reimbursement, the portion that is not reimbursed should be disclosed as a perk.

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