The Advisors' Blog

– Broc Romanek

A few days ago, I blogged that Corp Fin issued these 5 CDIs on Item 402(u). We’re posting memos in our “Pay Ratio” Practice Area.

I couldn’t help repeating this creative haiku about the CDIs, from this blog by Gunster’s Gus Schmidt:

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

Question 128C.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