On September 21, the SEC issued two interpretations intended to assist companies in preparing the pay ratio disclosures called for under Item 402(u) of Regulation S-K.
First is a formal SEC interpretive release providing guidance on:
- the use of reasonable estimates, assumptions and methodologies, and statistical sampling; and
- the use of internal records pertaining to non-US employees, the “median employee”, and independent contractors.
Second, the Division of Corporation Finance issued a separate announcement answering questions on a variety of estimating and sampling approaches.