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Helpful Recent SEC Guidance on CEO Pay Ratio Disclosure
Morgan Lewis Link to more items from this source
[Guidance Overview]
Oct. 5, 2017
"To identify the median employee, companies may use existing internal records, such as tax or payroll records, which reasonably reflect annual compensation, even if those records do not include every element of compensation, such as equity awards widely distributed to employees.... Previous guidance indicated that companies may apply statistical sampling and other methods to identify the median employee. The SEC has clarified that companies are permitted to combine methods, applying the ones that best suit the facts and circumstances."

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