2018 is the first year in which public companies have been required to report the “CEO Pay Ratio.” The CEO Pay Ratio for a reporting company represents the ratio of the total pay of the CEO to the total pay of the “median employee” at that company. This requirement is contained in Item 402(u) of Regulation S-K and applies to fiscal years beginning on or after January 1, 2017. (17 CFR §229.402(u).) It does not apply to emerging growth companies, smaller reporting companies and foreign private issuers.
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