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Webcast URL: https://www.theknowledgegroup.org/webcasts/ceo-pay-ratio-rule/

As the 2020 proxy season comes to a close, we reflect on the third year that CEO pay ratio disclosure under Section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act and Item 402(u) of Regulation S-K has been required annual disclosure for public companies. Compliance should be easier for companies that have already made pay ratio disclosures in 2018, 2019 and 2020. However, companies that have been using the same median employee will need to dust off employee census data and identify a new median employee next year whose compensation will be the basis of comparison. The impact of COVID-19 on the corporate workforce may also necessitate identifying a new median employee for companies that have initiated a reduction in force.

Listen as Shearman & Sterling's executive compensation experts Gillian Emmett Moldowan and Melisa Brower refresh the audience on the key provisions of the rule and discuss predictions about what’s to come now that year-over-year data is available. Although little attention has been paid to CEO pay ratio by the SEC to date, we anticipate that pay ratio may gain attention due to the availability of data from the SEC and various stakeholders.

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