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BNA Daily Labor Report Notes Greta Cowart-Coordinated Letter to SEC on Critical Dodd-Frank Requirements
08/09/2011
"Companies should be given at least two years following adoption of rules implementing Section 953(b) of the Dodd-Frank Act to comply with the requirement to disclose the ratio of chief executive officer pay to median employee pay, a group of practitioners said in a July 28 comment letter to the Securities and Exchange Commission.
The letter, in response to the agency's request for comments, expressed the individual views of 22 attorneys, all of whom support legislation that would repeal Section 953(b). In the event Section 953(b) is not repealed, the letter made several proposals addressing:
• foreign data privacy issues and the need to exclude non-U.S. employees of U.S.- based multinational corporations from the application of Section 953(b);
• alternative methods for calculating total pay of non-CEO employees, including use of W-2 compensation;
• use of a good-faith standard for employers’ determinations of median pay of employees; and
• choice of an alternative computation for reporting purposes—that is, the ratio of CEO pay to the average weekly earnings of private nonfarm workers, as published by the Bureau of Labor Statistics."
Excerpted from the BNA Daily Labor Report, July 29, 2011. To view the full article, click here (Subscription required.)
"I thank my wise and thoughtful colleagues who worked together to bring this to fruition," Ms. Cowart said, emphasizing that the entire team deserved the praise for its collaborative effort on this comment letter.
To read the full text of the letter, please click on the PDF link below.