SEC issues interpretive guidance on pay ratio disclosures
Sep 21, 2017
On September 21, 2017, the Securities and Exchange Commission (SEC) issued interpretive guidance, “Commission Guidance on Pay Ratio Disclosure.”
The interpretive guidance will “assist companies in their efforts to comply with the pay ratio disclosure requirement mandated by Section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act.” In addition, the SEC’s staff has issued guidance on the pay ratio rule that includes “hypothetical examples of use of sampling and other reasonable methodologies.”
Further, the staff of the SEC’s Division of Corporation Finance has updated the compliance and disclosure interpretations related to Regulation S-K to reflect the pay ratio guidance contained in the interpretive release. The update revises 128C.01, withdraws 128C.05, and adds 128C.06.
Review the press release, interpretive guidance, and staff guidance on the SEC’s website.