The Pay Ratio Rule: Disclosure and Compliance | Practical Law

The Pay Ratio Rule: Disclosure and Compliance | Practical Law

In 2015, the SEC adopted a rule requiring reporting companies to disclose the median annual total compensation of all company employees other than the CEO, the CEO's annual total compensation and the ratio between these two numbers. The rule is complex and offers companies flexibility in determining and disclosing their pay ratios. This Practice Note examines the pay ratio rule, including the options the pay ratio rule provides, and discusses steps companies can take to address any issues that arise in applying those options.

The Pay Ratio Rule: Disclosure and Compliance

Practical Law Practice Note w-000-6887 (Approx. 23 pages)

The Pay Ratio Rule: Disclosure and Compliance

by Practical Law Corporate & Securities. Based on materials contributed by Avrohom J. Kess and Yafit Cohn, The Travelers Companies, Inc. (formerly of Simpson Thacher & Bartlett LLP), with Bindu M. Culas and Michael R. Marino, Frederic W. Cook & Co., Inc.
MaintainedUSA (National/Federal)
In 2015, the SEC adopted a rule requiring reporting companies to disclose the median annual total compensation of all company employees other than the CEO, the CEO's annual total compensation and the ratio between these two numbers. The rule is complex and offers companies flexibility in determining and disclosing their pay ratios. This Practice Note examines the pay ratio rule, including the options the pay ratio rule provides, and discusses steps companies can take to address any issues that arise in applying those options.