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Text of SEC Memo: Potential Effect on Pay Ratio Disclosure of Exclusion of Different Percentages of Employees at a Range of Thresholds (PDF)
Staff of the Division of Economic and Risk Analysis of the U.S. Securities and Exchange Commission [SEC]Link to more items from this source
June 4, 2015

"Excluding some employees from the determination of median employee compensation, which some commenters suggested, can affect the calculation of that median and thus change the ratio of the annual total compensation of the principal executive officer (PEO) to the median of the annual total compensation of employees (pay ratio).... Projections ... are based on evidence obtained from other studies, aggregate statistics, and other assumptions that may result in over- or underestimating the magnitude of the effect."

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