Employment Flash - October 2015

SEC Adopts CEO Pay Ratio Rule -

The U.S. Securities and Exchange Commission (SEC) recently adopted a final rule requiring public companies to disclose the ratio of annual pay of their chief executive to median annual pay of all employees. While the pay ratio disclosure is required annually, the median employee calculation, which can be based on total employee population or a statistical sampling, generally need only be performed once every three years. Compensation of employees may be adjusted to account for the cost of living in the jurisdiction where the chief executive resides. Further, certain non-U.S. employees may be excluded from the calculation pursuant to foreign data privacy laws or if all employees in a specific non-U.S. jurisdiction constitute less than 5 percent of employees. Exemptions apply to certain emerging growth companies, smaller reporting companies and foreign private issuers. The rule, which was mandated by Congress pursuant to the Dodd-Frank Act, will become effective January 1, 2017...

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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