New disclosure rule presents an “apples and oranges” problem
As any communication veteran knows, every corporate “happening” creates a messaging opportunity. That is certainly the case with the impending round of pay-ratio disclosures. Starting this year, under an SEC amendment to Regulation S-K, which stemmed from a provision in the Dodd-Frank Wall Street Reform and Consumer Protection Act, most U.S. public companies will need to disclose the total annual compensation of their “median” employees, along with the ratio of that figure to the total compensation of their chief executive officers. Based on preliminary estimates, the highest ratios could exceed 350 to 1.