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To-Do List for Implementing Final Rules on the CEO Pay Ratio Disclosure
Winston & Strawn LLP Link to more items from this source
[Guidance Overview]
Aug. 6, 2015

"[1] Brief the board and/or compensation committee as to the final rules and the action steps.... [2] Each company may select a methodology to identify its median employee based on the company's facts and circumstances ... [3] Assess your ability to calculate precisely all items of compensation or whether reasonable estimates may be appropriate for some elements.... [4] Begin to evaluate possible testing dates.... Consider work-force restructuring ... [5] Determine whether any of your non-U.S. employees are employed in a jurisdiction with data privacy laws that make the company unable to comply with the rule without violating those laws."

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