We have been unable to find extensive SEC comments on last year’s first round of pay ratio disclosures. Searches for comment letter responses referring to for “402(u)” or “pay ratio” do not seem to turn up anything of general applicability.
Maybe the SEC staff determined that commenting on pay ratio disclosures would not materially benefit investor protection. Or maybe filings selected for review by the staff had materially complete disclosures. Who knows.
In any event, issuers can proceed towards proxy season knowing there are not any staff positions out there that are not clearly reflected in the rules.