SEC Issues Guidance on CEO Pay Ratio Rule
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On September 21, 2017, the Securities and Exchange Commission ("SEC") and the staff of the SEC’s Division of Corporation Finance issued interpretive guidance to assist public companies with complying with the “pay ratio” rule and to address compliance concerns with respect to the rule’s flexible framework. According to the SEC press release, “[the] guidance on pay ratio...encourages companies to use the flexibility incorporated in our prior rulemaking to reduce costs of compliance.” The new guidance provides some accommodations that publicly traded retailers may find useful for the purpose of calculating and reporting the ratio.

Read the full client alert.

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    Hannah focuses her practice on ESG and sustainability, securities law, and corporate governance for both domestic and international clients. Her experience spans advising on ESG reporting and governance, US securities laws ...

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    Scott brings in-depth knowledge of SEC policies, procedures and enforcement philosophy to each representation. Scott regularly advises clients across a broad sector of the economy facing sensitive reporting, compliance and ...

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