The ratio allows for comparisons between banks of different size and business mix. The companies included are among the biggest that focus primarily on Wall Street activities such as underwriting, trading and asset management and that disclose pay and employee figures for their investment-banking divisions.

Citigroup Inc. and Charlotte, North Carolina-based Bank of America Corp. don't break out compensation costs or personnel for their investment-banking divisions and feature large retail banks. Citigroup CEO Vikram Pandit earned 155 times the average pay expense for all workers at the New York-based bank, including tellers, while Bank of America's Brian Moynihan received 54 times the average pay for employees at his company.

Pandit, 55, was awarded $15 million for 2011, up from $1 the previous year. Moynihan, 52, received $7 million, down from $10 million.

'Executive Excess'

Section 953(b) of the Dodd-Frank Act instructs the SEC to require public companies to disclose the ratio between the compensation of their CEOs and employee medians. The late management theorist Peter Drucker said that the ratio should stretch no wider than 25-to-1.

CEO pay in the U.S. in 2010 was 325 times what workers averaged, according to the annual survey "Executive Excess," published by the Institute for Policy Studies, a Washington- based research group critical of high executive pay.

Compensation for bank CEOs raises "fairness questions" that go beyond spreads within their own companies, said Sarah Anderson, the organization's global economy project director and one of the authors of the study.

"They were one of the drivers of the crash that left a lot of people in horrible financial straits, and now they're bouncing back," Anderson said. "The problems aren't just how pay is structured, but when the overall levels of pay get so high, they encourage outrageous behavior."

'More Complex'

Another 2010 study, using a method similar to the one outlined in Dodd-Frank and conducted by Culpepper and Associates Inc., a compensation-survey firm based in Alpharetta, Georgia, found that the ratio was about 92-to-1 for companies with more than $2.5 billion in revenue.