Publication
Alert
SEC Issues Significant Guidance on Pay Ratio Disclosure Rules
Alert | By David Gordon, Michael Marino, Bindu Culas, Samantha Nussbaum
On September 21, the SEC released several documents interpreting the pay ratio disclosure rules required under the Dodd-Frank Wall Street Reform and Consumer Protection Act. In addition to implicitly confirming the widespread perception that the SEC plans to take no steps to modify the final regulations or delay implementation of the rule, the guidance provided some liberalization with respect to the procedures companies could use to compute the pay ratio. Notably, the SEC reversed its controversial position that, at least in some circumstances, independent contractors and leased workers had to be counted in computing the pay ratio.
David GordonManaging Director
Dave Gordon’s practice as an executive compensation consultant stretches back over a decade. He has covered a variety of industries, including extensive experience with financial institutions and utilities. In addition to engagements for his own clients.
Michael Marino
Managing Director & Head of New York Office
Mike works with a broad range of clients spanning most industries and across a wide spectrum of market cap and revenue, with considerable experience advising large, complex organizations. He provides advise on all aspects of executive compensation, including transformational business transactions and CEO employment negotiations. In addition, Mike works closely with private equity firms, their portfolio companies, and family-owned businesses.
Bindu Culas
Managing Director
Bindu Culas has over 20 years of experience advising clients on the US and international legal, tax and regulatory aspects of designing and structuring equity incentive programs, employment agreements, and severance and change-of-control plans.
Samantha Nussbaum
Principal
Samantha Nussbaum has consulted on behalf of public and private companies, compensation committees, and senior management on all aspects of executive compensation. Samantha’s consulting and legal background includes advising on executive compensation in the context of mergers and acquisitions, spin-offs, and initial public offerings; executive employment, severance, and change in control agreements; equity incentive plans; deferred compensation; and securities laws, including reporting and disclosure implications.