On September 21, 2017, the Securities and Exchange Commission (the “SEC”) released additional guidance on the pay ratio rules mandated under Section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which rule was adopted in August 2015 (the “pay ratio rule”). The SEC’s new guidance includes an interpretive release and additional guidance from the Division of Corporation Finance, as well as updates to the compliance and disclosure interpretations related to the pay ratio rule. To the disappointment of many registrants, in connection with its new guidance, the SEC confirmed that the pay ratio rule will take effect on schedule.
