SEC issues proposal to implement Dodd-Frank CEO pay ratio disclosure requirement
On 18 September, the Securities & Exchange Commission (SEC) proposed the adoption of new Item 402(u) of Regulation S-K to require public companies to disclose the ratio of their chief executive officers’ (CEOs’) total compensation to the median annual total compensation of all other company employees.
The new disclosure requirement is mandated by Section 953(b) of the Dodd-Frank Act and was announced in Release No. 33-9452. Emerging growth companies, smaller reporting companies and foreign private issuers would be exempt from the disclosure requirement. A company subject to the new requirement would first be required to disclose the CEO pay ratio for its first fiscal year beginning on or after the effective date of new Item 402(u).
Accordingly, if the SEC adopts the pay ratio proposal in 2014, calendar-year companies would not be required to provide the new disclosure until 2016, in their annual report on Form 10-K for 2015 and their 2016 annual meeting proxy statement…
If you are registered and logged in to the site, click on the link below to read the rest of the Hogan Lovells briefing. If not, please register or sign in with your details below.
News from Hogan Lovells
News from The Lawyer
Briefings from Hogan Lovells
The decision of the US Court of Appeals has raised questions about how issuers should present their disclosures on conflict minerals under Exchange Act Rule 13p-1 and Form SD.
An interesting judgment was delivered by the Honourable J Majiki on 19 November 2013 in the Eastern Cape High Court, Port Elizabeth.
Analysis from The Lawyer
As international firms question their future in these small, closely linked markets, local lawyers too are eyeing the business environment with caution
Beyond the headline infrastructure projects, UK construction work is still recovering from the clobbering it took during the slump