Subject: File No. S7-07-13
From: Anonymous

June 4, 2015

Investment banks and large multinational companies have outsourced a significant portion of their middle and back office work to shared services located in Singapore, India and the Philippines.  The wages of shared service employees must be included in the executive pay ratio.  These employees are performing services that benefit the head office back in the United States and other offices in developed countries.  

And don’t buy for a minute that data collection of overseas payroll poses undue hardship.  The reporting infrastructure for payroll for these companies are advanced and automated.  It is just an Excel file.

Anonymous