Section 953 (b) of the Dodd-Frank Act requires all listed firms to disclose a CEO-employee pay ratio. Firms are given the flexibility to use permitted discretions in their required pay ratio calculation and to disclose a supplementary pay ratio if necessary. We explore this unique regulatory setting and analyze the CEO-employee pay ratio data of S&P 1500 firms with fiscal year ends from December 31, 2017, through December 31, 2018. We find that both informational and opportunistic motives affect firms' supplementary pay ratio disclosure, while informational motives appear to dominate firms' use of permitted discretions. Firms consider political costs when using permitted discretions and disclosing a supplementary pay ratio. Firms with labor market signaling incentives disclose a supplementary pay ratio that is higher than the required pay ratio. The supplementary pay ratio, when issued, captures a firm's economic pay disparity better than the required pay ratio and is positively associated with subsequent firm performance.

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2020
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