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Posted by Lynne L. Dallas, University of San Diego, on Wednesday, April 19, 2017
Editor’s Note: Lynne L. Dallas is Professor of Law at University of San Diego School of Law. This post is based on Professor Dallas’ recent comment letter submitted to the SEC, available here.
On February 6, 2017 the Securities and Exchange Commission requested comments on further delay in implementing Section 953(b) of the Dodd-Frank Act that requires disclosure of CEO-employee pay ratios by public companies. This request should be analyzed in the context of a law that has been on the books almost seven years and has already been the subject of extensive public comments and SEC releases. Moreover, the SEC has granted to public companies considerable flexibility in calculating their ratios. These companies have substantial capabilities with today’s technology to collect and analyze data.
April 19, 2017 at 06:32PM
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