Thoughtful Disclosure Alerts

The CEO Pay Ratio Rule: Determining Your Employee Population

Download a pdf of this article » This Thoughtful Disclosure Alert has been revised to reflect the guidance issued by the Securities and Exchange Commission on September 21, 2017. Starting in 2018, public companies will be required to disclose in their annual report on Form 10-K and definitive proxy statement the ratio of the median of the annual total compensation of their employees (other...Read More

The CEO Pay Ratio Rule: The Foreign Employee Exemptions

Download a pdf of this article » This Thoughtful Disclosure Alert has been revised to reflect the guidance issued by the Securities and Exchange Commission on September 21, 2017. Starting in 2018, public companies will be required to disclose in their annual report on Form 10-K and definitive proxy statement the ratio of the median of the annual total compensation of their employees (other...Read More

The CEO Pay Ratio Disclosure Requirement – Time to Get Started

Download a pdf of this article » STARTING IN 2018, public companies will be required to disclose in their annual report on Form 10-K, definitive proxy statement, and certain other SEC filings the ratio of the annual total compensation of their Chief Executive Officer to the median of the annual total compensation of their other employees (the “Pay Ratio Rule”). This initial disclosure will be...Read More

With CEO Pay Ratio Effective Date Looming, There’s No Relief in Sight

As we mark the beginning of May, the January 1, 2018 effective date of the CEO pay ratio disclosure requirement is now only eight months away. Notwithstanding predictions following last November’s presidential election that this disclosure requirement would be quickly repealed, there has yet to be any action taken that would alter the looming effective date. Here’s where things stand as of May...Read More

SEC Staff Issues Guidance on CEO Pay Ratio Disclosure Rules

On October 18, 2016, the Staff of the Securities and Exchange Commission’s Division of Corporation Finance published guidance on Item 402(u) of Regulation S-K, the rule it adopted in 2015 to implement Section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Section 953(b) requires public companies to disclose the relationship between the annual total compensation of...Read More