The Advisors' Blog

– Liz Dunshee

I blogged last month about whether you can use the same “median employee” for your second year of pay ratio disclosure. This Pearl Meyer blog lists some other things to think about for Year 2 – but the main takeaway is to keep it simple. Here’s an excerpt:

Should you change your disclosure? After reading those nearly 4,000 other proxies, you may find yourself with a case of pay ratio disclosure envy and want to change the way your disclosure reads or is presented. Again, absent a compelling reason to do so (see our next two considerations), we would recommend retaining the same format and flow from 2018. With the SEC issuing zero comment letters on this disclosure requirement last year, it appears that every registrant has so far made a good faith attempt to comply and did (at least in the eyes of the SEC). Even proxy advisors and institutional investors didn’t complain about the disclosures, and if anything, said there was too much information. Why open yourself up to scrutiny by changing what has already worked?