May 16, 2012
I urge you to promptly issue a rule requiring public companies to disclose their ratio of CEO-to-worker compensation, as required by Section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
This pay ratio disclosure requirement will help boards of directors and investors evaluate the overall level of CEO compensation relative to other company employees.
The ratio of CEO-to-worker pay is material information for investors for many reasons. Academic studies show that large pay disparities within a company can hurt employee teamwork, productivity, loyalty and motivation. The impact of high levels of CEO pay on employee morale is particularly important in today’s weak economy, when workers are being asked to do more for less.
Since the information is aggregate, it does not appear that there are data privacy issues. If there are, then we ask that the Commission shares this with the public. At this time, there appears not reason keep this vital information private.
Thank you for your consideration