So much for Say on Pay being a game changer.

As I have been asserting for over a year, the advisory vote over whether to approve a company's executive compensation table has become something of a dud.

The investment fund of a major union activist is targeting the pay packages of two major pharmaceutical companies.

The American Federation of State, County and Municipal Employees (AFSCME), the largest public employee and health care workers union in the United States, is recommending that shareholders of both Pfizer and Johnson & Johnson vote against the executive compensation proposals at the annual meetings of both companies, which take place on April 28.

Shareholders and companies are on course for a major showdown over one of the provisions of the new Say on Pay mandate under the Dodd-Frank financial reform bill.

Under the rule, which the SEC made official earlier this week, companies must hold an advisory vote on its compensation table. This is a non-binding up or down approval for the entire group of executives.

 The anti-executive pay movement is building momentum.

About 55 percent of shareholders of KeyCorp last week gave the thumbs down on the bank's pay package contained in its proxy during an advisory vote.

 If the recent "no" Say- on- Pay votes at Motorola and Occidental Petroleum   indicate anything, it's that shareholder activism and populist ire regarding executive compensation have real legs. The majority of shareholders at those companies rejected proposed pay packages in a non-binding vote. But those decisions are only the tip of the iceberg, at least as far as changes to executive comp go.

In fact, over the last 24 months, public and shareholder pressure has led one in three Fortune 500 companies to change their executive pay plans, according to Doug Frederick, head of Mercer's Executive Benefits Group, who was quoted recently in  Plansponsor.com. And,  in case you were wondering, those changes generally haven't involved increases.

"Investors Reject Motorola's Pay Practices," exclaims the headline on the blog posted by RiskMetrics.

The proxy advisory firm said Motorola received just 46 percent support during an advisory vote on its executive pay practices, citing as its source investors who attended the company's May 3 annual meeting.

You have to hand it to Senator Chris Dodd. For someone who has heavily depended on the generosity of the largest banks and investment firms for his fund-raising, he has proposed a pretty impressive bill for further regulating the financial firms....given the current environment in Washington, of course.

I am not confident it will prevent another AIG, Lehman or Bear Stearns. The current poisoned partisanship in Washington on both sides of the aisle wouldn't support that kind of onerous bill.

The shareholder activist set is getting giddy over Say on Pay. They now count 50 companies agreeing to hold a non-binding up or down vote on the compensation table tucked into the proxy at the annual meeting.

This does not include all of the TARP recipients that are required to have annual advisory votes.