October 4, 2013
The statistics of CEO income should include anything a company gives an employee, across the board. That means all employees must be used to provide an accurate measure of the ratio of CEO pay to median worker payments and including material or physical assets.
From the proposal, page 11, "Where we have exercised discretion in implementing the statutory requirements, we are proposing alternatives that we believe will reduce costs and burdens, while preserving what we believe to be the potential benefits, as articulated by commenters, of the disclosure requirement mandated by the Dodd-Frank Act."
This is an inexcusable proposal and must be changed to meet the economic indicator that the Dodd-Frank Act requires, regardless of "costs and burdens." It should be defined not by "commenters" who are those being regulated and attempt to create loopholes to manipulate the data.