As reported by Broc Romanek in his recent blog post, the SEC recently posted five new CDIs related to the CEO pay ratio rules contained in Item 402(u) of Regulation S-K. In order to provide a very brief summary in a fun way, I’ve composed five haikus addressing the substance of each of the newly released interpretations. Enjoy!
Question 128C.01
A “CACM”
That reasonably reflects pay
Can be utilized
Question 128C.02
Hourly pay rates
Can we use to calculate?
No! These will not work
Question 128C.03
To calculate it
You must use recent data
90-day limit
Question128C.04
Furloughed employees?
You must include them too, but
Use annualized pay
Question 128C.05
What about ICs?
Ignore classification
If you set their pay