On June 4, 2015, the US Securities and Exchange Commission’s Division of Economic and Risk Analysis published additional analysis related to its proposed rules for pay ratio disclosure. Among other things, the analysis considers the potential effects of excluding different percentages of employees from the pay ratio calculation.

In September 2013, the SEC proposed rules that would require the disclosure of the median of the annual total compensation of all employees of the issuer, the annual total compensation of the chief executive officer of the issuer and the ratio of the median of the annual total compensation of all employees of the issuer to the annual total compensation of the chief executive officer of the issuer. The analysis and proposed rules are available for public comment until July 6, 2015. 

The SEC analysis is available at: http://www.sec.gov/comments/s7-07-13/s70713-1556.pdf and the proposed SEC rules for pay ratio disclosure are available at: http://www.sec.gov/rules/proposed/2013/33-9452.pdf