This site uses cookies to provide you with a more responsive and personalised service. By using this site you agree to our use of cookies. Please read our cookie notice ( for more information on the cookies we use and how to delete or block them.
The full functionality of our site is not supported on your browser version, or you may have 'compatibility mode' selected. Please turn off compatibility mode, upgrade your browser to at least Internet Explorer 9, or try using another browser such as Google Chrome or Mozilla Firefox.

SEC issues interpretive guidance on pay ratio disclosures

  • US_SEC Image

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 releaseinterpretive guidance, and staff guidance on the SEC’s website.

Correction list for hyphenation

These words serve as exceptions. Once entered, they are only hyphenated at the specified hyphenation points. Each word should be on a separate line.