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SHRM Comment Letter to SEC on Proposed Pay Ratio Disclosure Rules (PDF)
Society for Human Resource Management [SHRM] Link to more items from this source
[Opinion]
Jan. 2, 2014
"The Commission should limit the employees included in the identification of the median employee to those employed within the United States or who are paid through a U.S. payroll system.... The final rule should allow employers to annualize the compensation of non-full-time employees.... The Commission should establish a safe harbor method which provides for estimating median employee compensation, such as through the use of a formula or algorithm.... SHRM recommends that the initial compliance date be at least two years from the effective date of the final rule. Such a delay would allow employers to gather necessary information, and to review various approaches for compliance.... Finally, the pay ratio disclosure provided by registrants to the Commission should be considered to be 'furnished' rather than 'filed'.... By requiring that these disclosures be 'filed' in an annual or quarterly report, a registrant's chief executive officer and chief financial officer will be required to certify the accuracy of the disclosure pursuant to Section 302 of the Sarbanes-Oxley Act of 2002."

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