SEC Provides Guidance On Impending Pay Ratio Disclosure Requirements

On August 5, 2015, the Securities and Exchange Commission ("SEC") adopted final amendments to Regulation S-K to require disclosure by U.S. public companies of: (i) the median of the annual total compensation of all employees of the applicable company (excluding the principal executive officer); (ii) the annual total compensation of that company's principal executive officer; and (iii) the ratio of the median of the annual total compensation of all employees to the annual total compensation of the principal executive officer.

The pay ratio disclosure rules, which were mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, require companies to include pay ratio disclosure in public filings that call for executive compensation disclosure for fiscal years commencing on or after January 1, 2017. Thus, for companies with a fiscal year ending on December 31, this would generally mean that pay ratio disclosure would first be required in the annual