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News & Events Posted on: 9/13/2017
The fast-approaching 2018 proxy season marks the debut of the new CEO pay ratio disclosure rule.
Weighing in at a whopping 294 pages, the rule is a mix of general principles and explicit guidance that leaves no shortage of questions. Challenges range from gathering voluminous HR data to performing the calculation itself. The specific implementation hurdles vary from company to company.
As consultants who handle both the strategy and end-to-end computational aspects of the rule, we have a unique view into the practical realities of its implementation. In our conversations with hundreds of companies preparing for the rule’s inception, many of the same questions have come up over and over—questions about the rule’s survival and timeline, what the rule includes, the analysis process, and the proxy disclosure.
We spent the summer months preparing a detailed booklet capturing these common questions and our perspectives. If you’d like us to mail you a print version of the booklet, please request it here.
Join us for a question and answer session discussing the challenges associated with the new CEO pay ratio disclosure rule.
There may be uncertainty around the fate of Dodd-Frank. But absent formal intervention, the go-live date for the wildly controversial CEO pay ratio disclosure remains less than one year away.
On February 6, the SEC reopened the CEO pay ratio rule for a second comment cycle. The new comment period was open for 45 days, and the results were quite different from what most expected. We reviewed each comment letter and summarize the main trends here.