On September 21, 2017, the Securities and Exchange Commission (SEC) and the staff of the SEC’s Division of Corporation Finance issued interpretive guidance to assist public companies with complying with the “pay ratio” rule and to address compliance concerns with respect to the rule’s flexible framework. According to the SEC press release, “[the] guidance on pay ratio . . . encourages companies to use the flexibility incorporated in our prior rulemaking to reduce costs of compliance.” The new guidance provides some accommodations that publicly-traded retailers may find useful for the purpose of calculating and reporting the ratio.

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