SEC Adopts Pay Ratio Disclosure Rule

Morgan Lewis

Overview of the Pay Ratio Rule:

The Basic Rule -

Reporting companies subject to the rule (Subject Companies) must disclose the ratio (pay ratio) for the most recent fiscal year of (a) the median of total compensation of all employees of the Subject Company other than the principal executive officer (PEO) to (b) the compensation of the PEO.

• For purposes of this requirement, either (i) the ratio must present the amount in (a) as equal to one, or (ii) the ratio may be expressed narratively as the multiple that the amount in (b) bears to the amount in (a).

• Under the rule, Subject Companies must identify a “median employee” whose compensation will represent “the median of total compensation of all employees” for purposes of the rule.

Please see full White Paper below for more information.

LOADING PDF: If there are any problems, click here to download the file.

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.

© Morgan Lewis | Attorney Advertising

Written by:

Morgan Lewis

Morgan Lewis on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.