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SEC Provides New Guidance on Pay Ratio Disclosure Rule

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On September 21, 2017, the Securities and Exchange Commission (the “SEC”), as well as the SEC’s Division of Corporation Finance (the “Staff”), published new interpretive guidance to assist public companies in complying with the SEC’s pay ratio disclosure rule. The new guidance addresses many questions that have been raised regarding the rule, including how a company may identify the median employee whose compensation is to be disclosed under the rule, as well as the SEC’s enforcement posture with respect to pay ratio disclosures.

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