The SEC finally proposed the long-threatened “pay ratio” rules on September 18th. Required by the Dodd-Frank Act, the seemingly simple disclosure has been controversial from the start. If the 3-2 Commission vote did not highlight that fact, the more than 22,000 comment letters received before the proposed rules were released certainly do. The controversy stems from what many say is a harsh imbalance between the high cost of compliance and the low value for investors. Recognizing the issue, the SEC proposed rules that were designed to lower the cost of compliance while still meeting the requirements of Dodd-Frank.

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