SEC Acting Chairman Michael S. Piwowar issued a public statement on February 6, 2017 requesting input on any unexpected challenges that companies have experienced as they prepare for compliance with the CEO pay ratio rule, which will become required disclosure in public company 2018 proxy statements. Piwowar also directed SEC staff to “reconsider the implementation of the rule” based on comments submitted.

This public statement and request for comments is a first step in considering changes to the rule, as part of the Republican Party’s effort to modify or roll back certain provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd Frank). Any SEC modifications to the CEO pay ratio rule would take time to implement and may be challenged. The easiest route to prevent its implementation would be for Congress to repeal this provision of Dodd Frank.

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Photo of Alexander Song Alexander Song

Alexander Song is an Associate in the firm’s Employment, Labor & Benefits Practice and is located in the New York office. Alex’s practice focuses on all aspects of executive compensation for both public and private companies, including drafting of equity and incentive compensation plans and award agreements as well as employment, change-in-control, and severance arrangements for executive officers. He also prepares compensation discussion, analysis, and proxy statement compensation tables for public companies.

Photo of Pamela B. Greene Pamela B. Greene

Pamela B. Greene focuses her practice on securities compliance, executive compensation, and corporate governance matters. She advises public companies on compliance with the Securities Act of 1933, the Securities Exchange Act of 1934, stock exchange requirements, the Sarbanes-Oxley Act of 2002, and the Dodd-Frank Act of 2010. Pam works with management teams, boards, and compensation committees to develop and design appropriate executive compensation programs. She also advises public and private companies and individuals on executive compensation matters and provides executive compensation and securities counsel to clients in merger and acquisition transactions.