"Develop a process for collection of information, and consider a reasonable, documented approach to the calculation that is defensible to the SEC, investors and employees.... Conduct a simulated exercise ('dry run') of the pay ratio calculation and disclosure using 2017 compensation data as a baseline.... In drafting disclosures, consider how to frame the methodology, including assumptions, adjustments and any exemptions relied upon.... Provide the compensation committee with a draft of the CEO pay ratio disclosure as early as possible."  MORE >>