Under the Dodd-Frank Act (the “Act”), public companies will be required to disclose their CEO’s and the median employee’s pay, the ratio of the two, and an explanation as to how those results were derived.
While the Act did not provide an implementation deadline, the Securities and Exchange Commission (SEC) required that companies comply beginning with proxies filed in 2018. Recently however, Acting SEC Commissioner Michael Piwowar issued a public request for further comments as to the costs and burdens of the rule as written.
In response, Pearl Meyer solicited its clients to participate in an anonymous survey describing the impact of compliance with the rule to date. Some of the results of this survey were included in our letter to the SEC on March 23, 2017.
This summary includes key findings and broad analysis from the survey, as well as demographic details on the participating companies.
