The SEC has had many meetings with market participants about the requirement, which is "quite prescriptive," agency Chairman Mary Schapiro said last month during a Congressional hearing. Among other things, companies will have to consider the value of benefits when computing median compensation figures.

"There are a lot of burdens to making the calculation because it's an average of all employees that firms are really struggling with and we're trying to work through," Schapiro said. "It's not just that we could take the W-2 forms and come up with an average and then compare it to the CEO's compensation. It's much more complex than that."

SEC staff is working on a proposal that it intends to recommend to the commissioners in the first half of this year, according to a proposed timeline on the agency's website. The provision has no mandated deadline, Schapiro said.

'Fabulously Wealthy'

Some smaller companies have disclosed the data ahead of the requirement. Bond insurer MBIA Inc. disclosed the average and median pay in its proxy filing last month. Excluding the executive officers named in the filing, the median salary and bonus of its 373 employees was $180,000. The average salary and bonus was $247,200.

Jay Brown, CEO of MBIA, declined a bonus for last year's performance, collecting only his $500,000 salary. That would make his pay twice that of the average employee and 2.8 times the median.

Shareholders and regulators should want the ratio of CEO compensation to average pay to increase, since it serves more as an indicator of economic growth than as a breakdown of corporate governance, Johnson said. Still, Anderson of the Institute for Policy Studies said shareholders shouldn't be concerned about their executives' well-being.

"Even taking a year or two off from getting a bonus, in the grand scheme of things, they're still going to wind up fabulously wealthy at the end of their careers," Anderson said.

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