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ERISA and Global Benefits

SEC Pay Ratio Comment Letter – Paul Hastings Assists American Benefits Council

On March 23rd, the American Benefits Council submitted a comment letter to the SEC in order (1) to reiterate general opposition to the Dodd-Frank Act’s pay ratio disclosure rule; (2) to encourage the SEC to delay the effective date of its pay ratio disclosure rule; and (3) to propose cost-saving alternatives. In the latter respect, the Council’s suggestions include allowing issuers to use base pay alone when identifying their median-paid employees, and allowing the exclusion -- when making that determination – of independent contractors, part-time, seasonal, and temporary employees, and employees working outside the U.S.

Paul Hastings acted along with Davis & Harmon as outside counsel to the American Benefits Council with respect to this comment letter, and was led by Mark Poerio who serves on the Council’s executive board.  Please contact Mark if you have questions about the pay ratio rule or efforts to repeal or modify it.