"Compliance is likely to be time-consuming and expensive.... The rules allow for the identification of the median employee only once every three years -- maybe.... There is some flexibility in selecting a snapshot date to measure the number of employees.... No exclusions or adjustments allowed for part-time, temporary and seasonal employees.... Limited relief for public companies with operations outside of the United States.... Transition rule for mergers-and-acquisitions (M&A) transactions.... Supplemental pay disclosure and alternative ratios are permitted."