Rumor has it that, at the recent ABA Business Law Section Annual Meeting in Chicago, Corp Fin Director Bill Hinman confirmed—in case there was any doubt—that the pay-ratio rule would be in place for reporting in 2018.  

Presumably, that assumes no Congressional action that would preclude pay-ratio reporting or otherwise lead the SEC to rethink its rules.  And given all that’s on Congress’s plate these days, Congressional action on the pay-ratio rule seems rather unlikely. See this PubCo post.

In addition, expect new CDIs from Corp Fin in the next couple of weeks addressing areas of the pay-ratio rule where the SEC provided flexibility. (See this Cooley Alert.)

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