Subject: File No. S7-07-13
From: Mike Petty
Affiliation: Self-employed SW Engineer

October 21, 2013

Re: Response from NIRI

Please do not allow a policy think tank to guide your actions based on technical recommendations when clearly they have no technical experience. Also with the COEC, Center On Executive Compensation, such sampling is not only feasible, but completely mundane using standard SQL queries to run against any large database, Oracle, SAP, or ERP accounting structural data. Even statistical report building such as Crystal Reports does much of this analysis already. And as for multinational corporations, at any point in time, Forex and Libor provide data which makes internationalization of currencies a trivial task.

If the NIRI believes that the "average investor" as someone such as myself won't clearly understand the provided information, then we're all doomed. Yet here I am, an average investor, well versed in statistical methods.

If the NIRI believes that compliance costs will be exorbitant, then that company has simply hired the wrong group of consultants. Application development and report building by small dedicated teams is not only possible, it's how I continue to earn my living, and have done so for the past 10+ years.

If a previous company I consulted for has the ability to track and manage piece-part prices, with any number of value-add suppliers, of roughly 15,000 to 50,000 parts per machine in a current portfolio of 100's of machines, dating across decades of production, across currencies and time (future forecast and past history), then a simple weighted-mean of salaries ought to be trivial.

Meaningful statistical calculations should include either a standard deviation, or a weighted-mean fixed percent range (eg 5%, 10% or 20% ranges based on the number of employees being compensated within a range from bottom to top). This would provide a far more accurate picture when considering the possible scenario's of a significant portion of employee's work in a high cost of living city, or a significant number of employee's are highly compensated than a handful of individuals at the bottom.

Ratio's and percentages are useful for comparing one's own compensation to another target, in this case a C-suite individual. This information then provides insight when comparing the company you currently work for to others in your own field, or when comparing like groups of companies in a given industry. If these ratio's are troubling to the investor, they can dig deeper into why a particular board of directors feels they are entitled to such out-sized compensation. This information is not misleading at all.

Thank you for your consideration.