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SEC Issues Pay Ratio Rule Guidance!

By Randi Morrison posted 09-21-2017 04:37 PM

  
Hot off the press! Further to the report in yesterday's weekly Society Alert, the SEC just issued this interpretive guidance on the Pay Ratio Rule that reportedly:

  • States the Commission’s views on the use of reasonable estimates, assumptions and methodologies, and statistical sampling permitted by the rule
  • Clarifies that a company may use appropriate existing internal records, such as tax or payroll records, in determinations about the inclusion of non-U.S. employees and in identifying the median employee
  • Provides guidance as to when a company may use widely recognized tests to determine whether its workers are employees for purposes of the rule

The Division of Corporation Finance also issued guidance, which - according to Director Bill Hinman - "includes examples illustrating how reasonable estimates and statistical methodologies may be used" and "is intended to assist companies with their compliance efforts and reduce the costs associated with preparing disclosures," and these updated Reg. S-K C&DIs (revised Q 128C.01; withdrawn Q 128C.05; new Q 128C.06).

See this Reuters article, and stay tuned for additional information on Rants to Riches and in next week's Society Alert.
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