Oct 24, 2016
From the Financial Reporting View
The SEC staff recently issued five Compliance and Disclosure Interpretations (C&DIs) related to its pay ratio disclosure rule mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act. Registrants are required to disclose the ratio of the primary executive officer’s compensation to the median compensation of all employees in fiscal years beginning on or after January 1, 2017. The C&DIs address how a registrant may select and calculate a consistently applied compensation measure to identify its median employee if it does not use annual total compensation calculated using Item 402(c)(2)(x) of Regulation S-K.