SEC Issues Rule on Pay Ratio Disclosure
On August 5, 2015, the Securities and Exchange Commission (“SEC”) issued a final rule to implement the Dodd-Frank Act requirement that issuers disclose:
(A) the median of the annual total compensation of all employees of the issuer, except the issuer’s chief executive officer (or any equivalent position);
(B) the annual total compensation of the issuer’s chief executive officer (or any equivalent position); and
(C) the ratio of the amount described in subparagraph (A) to the amount described in subparagraph (B) (together, the “pay ratio disclosure”).