Pay Ratio

“A Sight for Sore Eyes”: New SEC Pay Ratio Guidance

What do public companies working to implement the pay ratio rules before next proxy season and Vince Gill circa 1989 have in common?  They have both seen a sight for sore eyes, as the guidance released by the SEC on September 21st provides issuers with increased flexibility and relief with respect to the pay ratio rules.  This client alert briefly summarizes the SEC’s seven-page interpretive release and the SEC staff’s related published guidance and updated Compliance and Disclosure Interpretations (“C&DIs”), all of which can be accessed easily at the SEC’s new website dedica