Corporate Governance Update
The Staff of the SEC’s Division of Corporation Finance published five new Compliance & Disclosure Interpretations (C&DIs) yesterday relating to the SEC’s CEO pay ratio disclosure rule required by the Dodd-Frank Act. The rule requires public companies to disclose the “pay ratio” between the CEO’s annual total compensation and the median annual total compensation of all other employees. The new C&DIs provide some clarity to companies as they prepare for compliance with the rule, including guidance relating to how companies identify a “median employee.” This Sidley Update summarizes the new C&DIs.
If you have any questions regarding this Sidley Update, please contact the Sidley lawyer with whom you usually work, or
Holly J. Gregory
+1 212 839 5853 John P. Kelsh
+1 312 853 7097 Thomas J. Kim
+1 202 736 8615 Corey Perry
+1 312 853 7797 Rebecca Grapsas
+1 212 839 8541 Claire H. Holland
+1 312 853 7099
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