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Gunster's securities law & corporate governance practice

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.

If you have any questions, please contact Gunster attorneys David Scileppi or Bob Lamm.


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