Bass, Berry & Sims attorney Jay Knight provided insight for an article outlining the details of the SEC's pay ratio rule, the latest regulation to the Dodd-Frank Act that was approved on August 5. The new rule, which first applies to fiscal years beginning on or after January 1, 2017, requires a company to disclose the ratio of CEO compensation to the median compensation of its employees. Accordingly, a company with a calendar year fiscal year must first include the disclosure in its Form 10-K or annual meeting proxy statement filed in 2018. As Jay points out in the article, " ... companies can start by reviewing the rule and working with senior executives to determine what the plan will be to arrive at a median employee compensation figure. 'If you can make a few adjustments now, that can lead to less complexity when you actually have to calculate the ratio'"
The full article, "Calculations Ahead: Complying With the SEC Pay Ratio Rule," was published by Corporate Counsel on August 7, 2015 and is available online (subscription required).