Jenner & Block

Client Alert: Final Pay Ratio Rule Doubles Down on Latitude for Companies; Requires Cross Border Privacy Analysis for Data of Foreign Employees

On August 5, 2015, the Securities and Exchange Commission voted to issue a final rule which requires certain public companies to disclose CEO-to-worker pay multiples.  Partners Bill L. Tolbert, Mary Ellen Callahan and Jolene Negre discuss how the disclosure is first required with respect to a company’s fiscal year beginning on or after January 1, 2017.  For companies with foreign employees, interaction with foreign data privacy laws may require consideration.