Katten Muchin gears up for pay ratio disclosure in 2018 proxy season

By Lene Powell, J.D.Despite perhaps fond hopes, the SEC’s Pay Ratio Disclosure rule remains in force and many companies will be dealing with it for the first time in the 2018 proxy season. Between lack of experience, data headaches, and potential public backlash, the required disclosures might be a real challenge for many companies. In a recent webinar, Katten Muchin partner Lawrence Levin and Amy Bilbija, a managing director at Strategic Governance Advisors, gave tips on preparing the disclosures and releasing the news to the public.Pay ratio disclosure. Adopted in 2015, the Pay Ratio Disclosure rule amended Item 402 of Regulation S-K to require covered registrants to disclose (1) the median of the annual total compensation of all employees of a registrant (excluding the CEO); (2) the annual total compensation of the registrant’s CEO; and (3) the ratio of these two numbers. Registrants must comply for the first fiscal year beginning on or after January 1, 2017.…

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