"The SEC's proposed rule will require most listed companies to disclose the following: The median of the annual total compensation of all employees, excluding the CEO; The annual total compensation of the CEO; The ratio of these two amounts. The SEC contemplates that its proposed rule may be effective for the 2016 proxy season. We expect, however, that the SEC will receive many adverse comments on the proposed rule, despite the flexibility that the rule is intended to permit, because the calculation of the median compensation will be burdensome -- particularly for large multinational companies."