On September 18, 2013, the Securities and Exchange Commission (SEC) issued a new rule proposal that would, if approved, require each affected public company to disclose the ratio of the median total annual compensation among all its company employees to the total annual compensation of its principal executive officer (the "PEO," as defined in Item 402(a)(3) of Regulation S-K).

The SEC also proposed that affected companies must tally the annual compensation of disparate types of employees, including full-time, part-time, seasonal and non-U.S. employees, in determining the median compensation among all employees.