Date: May 22, 2014

Issue: Pay Ratio

To: Members of the Senate Committee on Banking, Housing, and Urban Affairs; Members of the House Committee on Financial Services

Filing Type: Hill

Description: The Chamber study, which surveyed 118 companies, estimates the compliance costs of the Pay Ratio rule at $710.9 million with an annual compliance time of 3.6 million hours. This is in contrast to the costs estimates of the SEC in releasing the Pay Ratio rule of $72.7 million in costs and 545,792 hours of compliance time. Therefore, it is likely that the SEC has underestimated the costs by more than 870 percent and underestimated compliance time by 560 percent. Accordingly, the Chamber has requested that the SEC consider the Pay Ratio proposal an economic significant rulemaking and submit it to the Office of Information and Regulatory Affairs for an enhanced regulatory review process.

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