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CEO Pay Ratio Disclosure – Are You Ready?

Eastern Time

Cooley partner Amy Wood will be joining Mark A. Borges of Compensia for an ABA webcast on the topic of the new CEO pay ratio rule.

After a nearly 30-month wait, the new CEO pay ratio disclosure rule goes into effect in 2018. And in spite of the SEC’s decision to make its implementation requirements as flexible as possible, compliance will still be a challenge for most companies. The crux of the compliance process remains in identifying the “median employee” whose annual total compensation must be compared to the annual total compensation of the chief executive officer to produce the mandated “pay ratio.”

While the pay ratio rule and related commission guidance allows significant flexibility to comply in a manner that best fits your specific facts and circumstances, there are still many issues that must be carefully addressed. Further, drafting the required disclosure, particularly for 2018, will require careful calibration to ensure that the message to stakeholders strikes the right balance.

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Related Contacts
Amy M. Wood Partner, San Diego
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