Seven issuers voluntarily jumped the gun and provided pay ratio disclosures in their 2017 annual proxy statements. Reportedly, however, those disclosures were typically deficient:
The pay ratio disclosure provided by each of these registrants has generally been brief and, in certain cases, perhaps too brief. Only two of these registrants included disclosure that appears to fully comply with the final rule. Four registrants did not disclose the date on which the employee population was determined, and two registrants did not indicate the methodology used to measure compensation and identify the median employee. In addition, one registrant failed to express the relationship between the compensation amounts as a ratio and instead indicated a percentage—which is not expressly permitted by the final rule.[1]
[1] Winston & Strawn, Review of Voluntary CEO Pay Ratio Disclosure Yields Mixed Results (May 30, 2017), http://www.lexology.com/library/detail.aspx?g=09470ce5-e3c3-4afd-a705-92e856083c80
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