Photo of Bali Kumar

Bali Kumar is an associate in the Labor & Employment Law Department and a member of the Employee Benefits & Executive Compensation Group. Bali assists with representation of senior executives, compensation committees, companies and other entities on a range of executive compensation matters.

Prior to law school, Bali attended the London School of Economics where he earned a Masters of Science in International Employment Relations & Human Resources Management. Bali worked as an Executive Compensation Consultant for several years at Deloitte LLP where he advised on benchmarking total compensation packages, investor relations, compensation disclosure, and other corporate governance issues with regards to compensation strategy.

General:  The SEC recently released final pay ratio rules, which can be found here. As a new Item 402(u) of Regulation S-K, these rules codify the Dodd-Frank requirement for companies to disclose:

  • The median annual total compensation of all employees, excluding the Principal Executive Officer (“PEO”),
  • The annual total compensation of the PEO, and
  • The ratio of (i) and (ii).

The rules provide that this pay ratio must be expressed in a way that uses the median compensation as a base factor (i.e. 10 to 1, 10:1 or “the PEO compensation is ten times the median compensation”).