March 28, 2017

Pay Ratio: Comments Received So Far

Back in early February, the SEC’s Acting Chair – Mike Piwowar issued a statement directing the Corp Fin Staff to revisit the pay ratio rule & requested public comment about any challenges in complying with the rule. Comments were due within 45 days – so the deadline has now passed.

Here’s the list of comments received so far. Beyond a short form letter in favor of the rule (that was received over 3k times), there are several hundred comment letters. Most of these are short letters from individuals, also expressing an interest in keeping the rule. Overall, this new request for comment has resulted in a response that is a mere fraction of the 287k comment letters that the SEC received on it’s rule proposal.

Let’s dig down into these new comment letters. Only a handful of these letters are from companies explaining the challenges. But there are a few, like these:

Quest Diagnostics
Chesapeake Utilities
Finish Line
Flushing Financial
Stein Mart
National Association of Manufacturing (citing situations of anonymous companies)

There are a number of comment letters from institutional investors, including:

Group of Couple Hundred Investors, Unions & Others (posted as “Aberdeen Asset Management”)
Everence Financial & Praxis Mutual Funds
Walden Asset Management
Trillium Asset Management

And there’s a few from unions:

International Brotherhood of Teamsters

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Broc Romanek