I hope this note finds you well and you are enjoying the start of your summer.
I wanted to let you know that I have been invited to speak at the Boston/Connecticut NASPP Chapter's regional conference on Monday, July 14, 2014 on the proposed pay ratio rules. The conference is at Fidelity's offices in Boston and it's free. Here's a link with more information: NASPP Connecticut Chapter Events.
The focus of the presentation is on the use of statistical simulation as a possible approach to find the "median employee" for purposes of determining the pay ratio. The SEC's proposed rules place considerable emphasis on the use of statistical sampling as a way to reduce the costs associated with computing the ratio of CEO pay to median pay at companies. While sampling might be helpful at a number of companies, I'm not convinced it will result in significant cost savings if the data are accessible to sample - why not array the data if you have them? The concern I have is for companies that simply do not have access to all pay data (e.g., recently acquired business units located outside of the US). If these companies are able to obtain quartile data for these units, then simulation might be a practical approach to fill any gaps in the company's overall pay data.
Here is a copy of the presentation: Pay Ratio: "Other Reasonable Methods." Let me know what you think.
I hope I will see you in Boston.
Talk to you soon.
Andy
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