Call to Action
The U.S. Securities and Exchange Commission has asked issuers to submit comments on the challenges and costs they face in preparing for the agency's CEO pay ratio rule. This Dodd-Frank mandate would require most U.S. public companies to disclose the ratio between the total compensation received by their CEO and that earned by the issuer's median employee. Companies with December 31 fiscal years would have to make their first disclosures in the spring of 2018. NIRI plans to submit a comment letter that asks the SEC to delay this rule and to reduce the scope of the pay ratio calculation to full-time, U.S.-based employees, which would reduce compliance costs for many issuers. Please send in input about the challenges and costs your company would face to Ted Allen, NIRI's director of regulatory affairs, at by Friday, March 10


NIRI Comment Letters

NIRI Comment Letter on the SEC's Concept Release on the Business and Financial Disclosure Required by Regulation S-K (August 2016)

NIRI Comment Letter on the SEC's "Pay vs. Performance" Rule (July 2015)

NIRI Comment Letter on the SEC's Strategic Plan (March 2014)

NIRI Comment Letter to the SEC on Pay Ratio Disclosure (October 2013)