Subject: File No. S7-07-13
From: Jim Meyer

October 18, 2013

The proposed pay ratio disclosure rule has noble intentions, but is reckless in its burdensome detail and predictably incomparable results. CEO pay is disclosed in tremendous detail in public company proxies. If it is inappropriate, the Board and/or shareholders should act. If it is market-appropriate and the company is delivering reasonable returns, it is not important or meaningful that the CEO makes a certain multiple of the wages of his/her multinational workforce.

Workforce wages should be appropriate to the nation where the work takes place. The wages and working conditions should be compliant with local laws. If wages are low or the working conditions are lacking, then the company will lose its employees to others, and will be forced by the market to make adjustments.

I am not sure, other than political symbolism, what this rule is meant to achieve.