"The pay ratio disclosure requirements have elicited a fair amount of controversy and criticism, mostly due to a perceived high cost of calculating the ratio as compared to the value to investors of the information provided by the disclosure. In recognition of the complexity and cost that many public companies will face in complying with the disclosure requirements, particularly those with a significant global presence, the SEC's proposed regulations provide some flexibility in the methodology that may be used by an issuer in making the pay ratio calculations. However, there will still be challenges for many issuers to properly comply with the requirements."