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SEC Proposes CEO-to-Median Employee Pay Ratio Disclosure Rules
Faegre Drinker
[Guidance Overview] Sept. 19, 2013 "The disclosure of the company's methodology, including assumptions, adjustments and estimates used, should provide enough information for an investor to evaluate the appropriateness of the calculation.... [If] statistical sampling is used, the company should disclose the sample size, the size of the whole population, the sampling method and how differences in systems or geographies were handled. Changes in assumptions, adjustments or estimates from one year to the next should also be identified, including the reason for the change and the estimated impact of the change on the median and the ratio." MORE >> |
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