Hot Topic: CEO Pay Ratio

Here’s a resource center for HR, finance, and accounting professionals who want to get on top of Dodd-Frank CEO pay ratio disclosure rules.

The Dodd-Frank Wall Street Reform and Consumer Protection Act, which requires most public companies to regularly report the total annual compensation ratio of the CEO compared with the median employee, became law in 2010. Five years after that—on August 5, 2015—the SEC issued its final ruling. And so here we are.

On this page, you’ll find everything we’ve published on pay ratio. This includes tips for calculating and disclosing the pay ratio, as well as ways to overcome challenges we’ve seen our clients run into.

Need more? We’re here to help. Look into our pay ratio disclosure services or contact us directly.


What You Need to Know About the September 2017 SEC Pay Ratio Guidance

On September 21, 2017, the SEC released additional pay ratio guidance. The new guidance primarily reiterates and clarifies flexibility that the rule already allowed, with one substantial update. In this blog post, we go over the highlights of the interpretive guidance and updates to the Compliance and Disclosure Interpretations, and we discuss the ideas posed in the Department of Corporate Finance guidance regarding statistical sampling.

David Outlaw, and Alec Katric · 10/11/2017


CEO Pay Ratio: 40 Frequently Asked Questions and Answers

Weighing in at a whopping 294 pages, the CEO pay ratio rule is a mix of general principles and explicit guidance that leaves no shortage of questions. In this booklet, we share some of the common questions that have come up and offer insights that may prove relevant in the course of your preparation. Reserve your copy today.

Takis Makridis, Josh Schaeffer, PhD, David Outlaw, and Alec Katric · 9/10/2017


CEO Pay Ratio: 15 Burning Questions Answered

Join us for a question and answer session discussing the challenges associated with the new CEO pay ratio disclosure rule.

Takis Makridis and David Outlaw · 8/29/2017


The SEC Reopened Comments to the Dodd-Frank Pay Ratio Rule. Here’s What the Public Said.

On February 6, the SEC reopened the CEO pay ratio rule for a second comment cycle. We reviewed each comment letter and summarized the main trends here.

Josh Schaeffer and David Outlaw · 5/8/2017


A Practitioner’s Guide to Pay Ratio Project Management

In this implementation-oriented guide, we break down CEO pay ratio planning and execution into 10 steps and include a quick reference checklist to help steer your efforts.

Josh Schaeffer and David Outlaw · 3/8/2017


The Destiny of Dodd-Frank’s Executive Compensation Provisions

With the fate of Dodd-Frank up in the air, we take a look at the current state of the law, and analyze what could happen next.

Takis Makridis · 2/28/2017, updated on 6/13/2017


CEO Pay Ratio is Here – How to Prepare

CEO pay ratio is sure to be one of the big challenges of 2017 for equity compensation professionals. In this webcast, we provide an overview of what you can do to prepare for calculating and disclosing the ratio.

Takis Makridis · 11/16/2016


Pay Ratio CDI: What You Need to Know

In an effort to clarify aspects of its original pay ratio guidance, the SEC released additional Compliance and Disclosures Interpretations (CDI) on October 18, 2016, with 5 questions and corresponding answers. Read the CDI, as well as our perspective on it here.

Takis Makridis, Alec Katric, and David Outlaw · 11/14/2016


You’re Missing Compensation Data for Your Pay Ratio Calculation. How Do You Find the Median Employee?

As companies prepare for the new CEO pay ratio disclosure requirement in 2017, many are running into the problem of missing employee data, especially in international jurisdictions.

Josh Schaeffer · 10/14/2016


Surfing the Coming Pay Ratio Wave with Confidence

View the slides from this presentation on pay ratio calculation methodology and contextualizing results in the proxy, delivered at the 2016 World at Work Conference in San Diego.

Nathan O’Connor · 6/17/2016


Q&A on New Regulations From the FASB and SEC

Get answers about how these updates will affect the 10-K, the proxy, the compensation committee, finance and accounting processes, and more.

Takis Makridis · 5/12/2016


Population Analysis: An Easier Way to Identify Median Employee Pay

In this April 2016 Workspan article, we explain why population analysis can beat sampling methods when disclosing your CEO pay ratio.

Josh Schaeffer and Nathan O’Connor · 5/10/2016


CEO Pay Ratio: An Update from the Field

Here’s what we’ve discovered between our own research, consulting with other experts, and helping companies develop their pay ratio calculations.

Takis Makridis · 3/4/2016


Dodd-Frank 5 Years On – The Adventure Continues

Download this on-demand webinar for an overview of where things stand plus a primer on specific Dodd-Frank rules.

Nathan O’Connor · 3/4/2016


How Many is Enough? Sample Selection and CEO Pay Ratio Accuracy

Statistical sampling makes it too easy to fall short of meeting the burden of representational faithfulness in the SEC’s guidance.

Josh Schaeffer and Therese Sebastian · 12/8/2015


A Five-Minute Guide to Pay Ratio Disclosures

In this article, published before the SEC finalized its pay ratio disclosure rules, we argue that companies should consider the requirement an opportunity to add narrative and supplementary numerical color to their disclosures.

Takis Makridis and Therese Sebastian · 8/5/2015