The Advisors' Blog

– Broc Romanek

Here’s the intro from this memo by Andrews Kurth Kenyon’s Tony Eppert & Mike O’Leary:

Many public issuers that are master limited partnerships (“MLPs”) or real estate investment trusts (“REITs”) have no employees, and instead, are externally managed by a related entity pursuant to a service agreement. This fact pattern, which is common to MLPs and REITs, raises a question of whether the issuer has to comply with the pay ratio disclosure rules of Item 402(u) of Regulation S-K if neither it, nor any of its consolidated subsidiaries, have employees.