On June 4, 2015, the SEC staff issued additional analysis related to the September 2013 rule proposal that would implement the "pay ratio" disclosure requirement mandated by Section 953(b) of the Dodd-Frank Act. The additional analysis, made by the Division of Economic and Risk Analysis, considers the potential effects of excluding different percentages of certain categories of employees (such as part-time, seasonal or temporary employees or employees in foreign countries) on the pay ratio calculation.

The SEC staff is accepting public comments on the analysis until July 6, 2015.

For more details on the pay ratio proposal, see Legal Update, SEC Proposes Dodd-Frank Pay Ratio Disclosure Rules.

For more information on executive compensation disclosure, see Practice Note, Proxy Statements: Executive Compensation. For information on provisions of the Dodd-Frank Act relating to executive compensation, see Practice Note, Summary of the Dodd-Frank Act: Executive Compensation.