November 28, 2014


Deadline for Adoption of Final Pay Ratio Rules Pushed Back by SEC

The SEC recently updated its regulatory agenda. As part of the update, the deadline to adopt final pay ratio rules was pushed back to October 2015 (from October 2014).

  • Implication: companies with a Dec 31 fiscal year end are not expected to be required to comply with pay ratio rules/disclosure until publication of 2017 proxy statements

The deadline for other outstanding compensation-related rulemaking coming out of the Dodd-Frank Act was also delayed to October 2015: standardized pay vs. performance disclosure, hedging policies, and clawbacks requirements.

  • Note: Timeline changes reflect a new deadline, not the date at which rulemaking will be published or adopted

We will provide additional updates as this issue continues to evolve.