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ARTICLE · 23 SEPTEMBER 2015

SEC Adopts Final Pay Ratio Disclosure Rules

Duane Morris LLP
Duane Morris LLP
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The final rules provide a registrant with flexibility in determining its median employee, permitting the use of its entire employee population, a statistical sample or other reasonable methods for this purpose.

United StatesCorporate/Commercial Law

The U.S. Securities and Exchange Commission (SEC) has adopted final pay ratio disclosure rules under the Dodd-Frank Wall Street Reform and Consumer Protection Act. Under the new rules, a covered registrant will be required to provide annually, as more fully discussed below, the following information:

(a) the median of the annual total compensation of all employees of the registrant (excluding the CEO);

(b) the annual total compensation of the registrant's CEO; and

(c) the ratio of the CEO's annual total compensation to the amount described in (a).

The following questions and answers discuss the most important provisions of the new rules. 

Which registrants are covered under the new rules?

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