On Aug. 5, 2015, the Securities and Exchange Commission (SEC)
adopted a final rule implementing the CEO pay-ratio
disclosure requirements of Section 953(b) of the Dodd-Frank Wall
Street Reform and Consumer Protection Act.
The final rule provides that starting with their first annual
report, annual proxy or information statement filed for fiscal
years beginning in 2017, each public company (other than smaller
reporting companies, emerging growth companies and foreign private
issuers) will need to disclose as a ratio or multiple how the
annual total compensation of its principal executive officer (PEO)
compares to the annual total compensation of its median employee.
This means that for a calendar-year issuer that is not exempt, the
first time it will need to provide the disclosure will be with its
annual report or annual proxy or information statement filed in
2018 for its 2017 fiscal year, which represents a one-year
additional delay in the effective date, as compared
