Society of Corporate Secretaries & Governance Professionals’ The SEC's Pay Ratio Proposal
September 25, 2013
Overview
On September 25, 2013, Cleary Gottlieb partner Arthur Kohn, as part of the Society’s Governance Minutes series, discussed the SEC’s proposed pay ratio rule implementing Section 953(b) of the Dodd-Frank Act, which requires disclosure by reporting companies of the median annual total compensation of all their employees and the ratio of that median to the annual total compensation of their chief executive officers.
Disclosure would likely first be required for calendar year companies in 2016 proxy filings relating to 2015 compensation. Mr. Kohn discusses likely timing for implementation, the SEC approach to the rulemaking, what companies are doing now, and some key aspects to keep in mind as the rule moves to potential adoption.
