SEC Publishes Helpful Guidance On Pay Ratio Disclosure

Summary

The SEC recently confirmed that the new CEO pay ratio disclosure rules mandated in the Dodd-Frank Act will go into effect in the 2018 proxy season. To assist companies in preparation of the new disclosure, the SEC published interpretive guidance on September 21, 2017.

In Depth

Despite some speculation that the new leadership within the Securities and Exchange Commission (SEC) would seek to delay the effectiveness of the CEO pay ratio disclosure rules mandated by the Dodd-Frank Act, the SEC recently confirmed that the new disclosure will go into effect, as scheduled, in the 2018 proxy season. To assist companies in preparing for the new disclosure, the SEC published interpretive guidance (Commission Guidance) on September 21, 2017. The Staff of the Division of Corporation Finance published its own interpretive guidance and updated its Compliance and Disclosure Interpretations (Staff Guidance) on the same date.