"The members generally agreed that the Commission has done an admirable job in proposing to implement Section 953(b) in a flexible manner that attempts to strike an appropriate balance between providing potentially useful information to investors and limiting company compliance costs.... Two of the three members were 'not comfortable' with the proposed exemption from the pay ratio disclosure requirements for emerging growth companies, smaller reporting companies, foreign private issuers, and MJDS filers .... The three members generally agreed with the SEC that, consistent with the language of Section 953(b), all employees, including non-U.S. employees, should be considered in the calculation of the median[.]"  MORE >>