Market Trends 2022/23: Pay Ratio Disclosure

Summary

This practice note discusses the U.S. Securities and Exchange Commission's (SEC) pay ratio rulemaking, which was mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (111 Pub. L. No. 203, 124 Stat. 1376), and provides recent pay ratio disclosure examples. The SEC originally proposed pay ratio disclosure in 2013, and the proposal generated a great deal of interest and debate. The final rule was adopted in 2015 and required pay ratio disclosure by companies with respect to their first full fiscal year beginning on or after January 1, 2017.