Complying With SEC Final Rule on Disclosure of CEO-Median Employee Pay Ratio

Overview of Pay Ratio Disclosure Rule

On Aug. 5, 2015, in a narrow 3–2 vote of its five commissioners, the Securities and Exchange Commission settled a heated debate when it adopted a final rule that requires certain publicly traded companies to disclose the gap in pay between the company’s chief executive officer (CEO) and its median worker 151 PBD, 8/6/15, 13 WLR, 8/14/15, 29 LRW 1644, 8/12/15, 33 HRR 847, 8/10/15, 151 DLR A-7, 8/6/15.

The SEC adopted the rule to comply with Section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). Section ...