On June 4, the staff of the Securities and Exchange Commission (Staff) released analysis related to its proposed rules for pay ratio disclosure, which analysis evaluates the potential effects of excluding different percentages of employees from the pay ratio calculation. In announcing the issuance of this analysis, the SEC stated that its Staff “believes that the analysis will be informative for evaluating the potential effects on the accuracy of the pay ratio calculation of excluding different percentages of certain categories of employees, such as employees in foreign countries, part-time, seasonal, or temporary employees as suggested by commenters.”.

For a link to the analysis, click here.