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SEC Issues Final Rule on CEO Pay Ratio Disclosure
Winston & Strawn LLP Link to more items from this source
[Guidance Overview]
Aug. 5, 2015

"[T]he rule will not require companies to report the pay ratio disclosure for any fiscal year beginning before January 1, 2017, which means, for most companies, reporting in the 2018 proxy statement.... The final rules [1] allow a company to select a date within the last three months of its last completed fiscal year on which to determine the employee population for purposes of identifying the median employee.... [2] only allow a company to exclude non-U.S. employees from the determination of its median employee in two circumstances ... [3] prohibit companies from full-time equivalent adjustments for part-time workers or annualizing adjustments for temporary and seasonal workers when calculating the required pay ratio."

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