I was reminded of this need after discussing 2011 compensation trends with three compliance experts at The Hay Group. Irv Becker Economics, who leads the firm’s U.S. compensation practice, suggested that I also consider another provision in the new regulation — “Additional Disclosure Requirements” – likely to require a significant amount of reflection and work.
Earlier this week, I discussed the “say on pay” provision within the Dodd-Frank Wall Street Reform and Consumer Protection Act. It’s something I will be writing about quite a bit in the coming month – without overdoing it.
This provision of Dodd-Frank requires companies to disclose “the median of the annual total compensation” of all of the company’s employees excluding the CEO, the annual total compensation of the CEO, and the ratio between the two. So, this provision will also require a significant amount of calculating. This article can help you and/or your compensation committee to be prepared when it comes time to conduct the reflection, math Economics, and legwork the law’s new disclosures require. ###
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