• SEC Proposes Rule for Pay Ratio Disclosure
  • October 7, 2013
  • Law Firm: Kilpatrick Townsend Stockton LLP - Atlanta Office
  • On September 18, 2013, the Securities and Exchange Commission (the “SEC”) published a proposed rule that would implement Section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act by amending Item 402 of Regulation S-K to require a public company to disclose the ratio of the median compensation of its employees to the compensation of its chief executive officer (“Pay Ratio Rule”). Specifically, the proposed disclosure must include: (1) the median of the annual total compensation of all employees of the registrant, except the principal executive officer (“PEO”); (2) the annual total compensation of the PEO of the registrant; and (3) the ratio of the median compensation of all the employees to the annual compensation of the PEO. In addition, the registrant must briefly disclose any methodology used to identify the median and any material assumptions, adjustments or estimates used to identify the median or to determine total compensation.