SEC issues new and revised guidance on CEO pay ratio rule

On September 21, the SEC and the staff of the Division of Corporation Finance issued new and updated interpretive guidance regarding the CEO pay ratio disclosure required by Item 402(u) of Regulation S-K. The guidance consists of three parts: an SEC interpretive release; staff guidance concerning the use of statistical sampling and other methods for identifying the median employee; and new and revised staff Compliance and Disclosure Interpretations (CDIs).

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