"[T]he SEC has provided companies with substantial flexibility ... for determining employee compensation and has allowed the use of simplified compensation measures to identify the company's median employee ... The rules are most inflexible and administratively expensive and burdensome in requiring that all employees of a company and its subsidiaries (broadly defined) be taken into account in identifying the median employee ... During the next 60 days, companies should determine how they would go about gathering and analyzing the information necessary to comply with the rules and should file comments with the SEC discussing the costs and burdens of doing so, using the SEC's 69 requests for comments as a guide."