The Advisors' Blog

This blog features wisdom from respected compensation consultants and lawyers

November 13, 2013

Should Pay Ratio Disclosure Be “Furnished” or “Filed”?

Broc Romanek, CompensationStandards.com

Here’s an interesting blog from Blank Rome’s Yelena Barychev about whether pay ratio information should be deemed “furnished” and not “filed” for purposes of the Securities Act of 1933 and Securities Exchange Act of 1934…

Come participate in today’s spreecast: “Crafting SEC Rulemaking Comment Letters.” During it, Hunton & Williams’ Scott Kimpel and Bass Berry’s Jay Knight will describe how to best craft a persuasive comment letter on a SEC rulemaking. This will certainly be handy for those of you writing in on the SEC’s pay ratio proposal. To access the spreecast, go here at 1 pm eastern. [Note last month’s “Latest Corp Fin Comment Letter Trends” spreecast has had over 500 views.]

Here are FAQs about how spreecasts work – but the upshot is you have to register for Spreecast first (although it’s possible to watch without registering if you close a prompt). Simply sign up by using an email address by clicking the “Or sign up via email” link in the upper right hand side of the site (it’s in small print under the “Connect with Facebook” logo).