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SEC Proposes Pay Ratio Disclosure Rules Under the Dodd-Frank Act

September 24, 2013

By GISLAR DONNENBERG, MARK POERIO, MIKE BLANKENSHIP, MATT HENDRIX & LESLIE OGUCHI

On September 18, 2013, the Securities and Exchange Commission proposed rules that would require U.S.-based public companies to disclose the pay gap between their chief executive officers and their median rank-and-file employees. Issuers had feared onerous administrative burdens, but received significant flexibility that ultimately seems to present the greatest challenges for multi-national employers having de-centralized payroll systems.