New CDIs Help Issuers With Pay Ratio Disclosure, A Little

On October 19th, the SEC released five new Compliance and Disclosure Interpretations (“CDIs”) relating to the upcoming “Pay Ratio Disclosure” requirements in Item 402(u) of Regulation S-K. Item 402(u) Pay Ratio Disclosure requirements, mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act, require each covered public company to make annual disclosure of the ratio of its principal executive officer’s total annual compensation to the total annual compensation of an individual whose compensation is determined to be the median compensation of all of the company’s employees. Read our complete summary here:

Whitney Holmes

Whitney is a Partner in the Corporate Governance and Compliance Law group. He has represented public and private enterprises in corporate finance transactions, including: public offerings and private placements of equity and debt securities; bank credit financings; structured financings and other capital markets transactions; and venture capital financings. He has represented issuers and underwriters in several large and complex securities transactions, and has represented both banks and borrowers in large and highly structured borrowings. His representations extend from pre-inception planning through structuring and execution and he has worked on several novel and market-leading transactions.

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