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How Comment Letters Could Shape the Pay Ratio Rule

Joe Mont | July 28, 2015

Ask and thou shalt receive. When the Securities and Exchange Commission proposed its controversial pay ratio disclosure rule in 2013, it included a list of nearly 60 questions for public comment.

The response:  287,547 letters and counting.

Granted, tens of thousands of those missives were form letters prodding for the SEC to hurry up and finish the rule, which would require public companies to disclose the ratio of CEO pay to that of the median employee. Many more, however, did include suggestions for making the rule workable and less of a compliance burden.

According to persistent rumors, a final version is due to arrive sometime later this summer (believe that when you see it)—but already the proposal is one of the most commented-upon in SEC history. We took a look at some of the more intriguing suggestions so far that might influence what arrives in final form.

Employee Exclusions?

A common concern has been the international scope of...

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