Regulatory Alerts2017-09-27 | 2017-20632Added
Commission Guidance on Pay Ratio Disclosure
The Securities and Exchange Commission issued interpretive guidance to assist registrants in complying with pay ratio disclosure requirements under Item 402(u) of Regulation S-K. The guidance clarifies that companies may use reasonable estimates, assumptions, statistical sampling, and existing internal records like payroll or tax data to identify the median employee and calculate compensation. It further confirms that registrants may apply widely recognized tests from other legal contexts to distinguish between employees and independent contractors for this purpose.
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