Annual Total Compensation under the Pay Ratio Disclosure Rule

Although adopted back in 2015, the SEC’s pay ratio disclosure rule has been receiving a lot of attention lately, as companies grapple with it for the first time during the 2018 proxy season. The rule was mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act and generally requires a public company to disclose in its proxy statement the pay ratio between its chief executive officer and its median employee for the most recently completed fiscal year. In particular, the rule requires disclosure of each of the following items: READ MORE