SEC Pay Ratio Disclosure Comment Letter

On December 1, 2013, NACD submitted a comment letter to the SEC on the proposed rule for pay ratio disclosure. Reflecting the views from recent surveys of our members, as well as the values implicit in the findings of NACD’s thought leadership groups, this letter also incorporates perspectives from NACD chapter leader roundtables, director forums, director education programs, and other events focused on promoting effective governance practices.

In this letter, NACD remarks on behalf of the director community, asking that the SEC increase the flexibility of this rule by permitting use of industry averages, by limiting employees to full-time domestic employees, and by permitting supplemental notes to correct any distortions caused by the use of “total pay” figures.