On September 18th, the SEC published for comment proposed new rules that would require a public company to disclose the ratio of the compensation of its CEO to the median compensation of its employees. The new rule, required by the Dodd-Frank Act, would not prescribe a specific methodology for calculating the ratio but would allow a company to choose an appropriate methodology, including one that employs statistical sampling and reasonable estimates. Comments should be submitted within 60 days after publication in the Federal Register, which is expected shortly. SEC Press Release.