Subject: File No. S7-07-13
From: Dory Storms

September 24, 2013

I’m writing in support of a strong Dodd-Frank rule 953(b).

For many reasons I support disclosure of corporate pay ratios (CEO pay: average employee py). Transparency and accountability should be the gold standard expected of corporations, government and citizens alike. Executive pay is not a homeland security issue, and businesses are not aiding terrorism if they disclose corporate pay ratios.  However, extreme lop-lopsidedness of the ratio does call into question the priorities of a business, and consumers and investors need to have that information. 

Extreme differences between those who actually produce the goods or sales, and those who "direct" operations,also brings into question how solid our democracy. When workers are squeezed by stagnant pay levels, pay inequities grow, and the rich get richer as their peers on boards give them pay increases and bonuses. The resuls is that the executives stand increasingly apart from those who work for them, serve them. produce for them. That's America?  No, sounds to me very much like life in Latin American plantation economies. 

Disclosing corporate pay ratios between CEOs and average employees is extremely informative about the priorities of a business and those of our country. It is not difficult to calculate corporate pay ratio from the data, (if available), even for a fourth grader.  But, it is something that executives resist, and they have the political lobbying power and large  amounts of cash to attempt to influence both legislators and bureaucrats, but also fund slanted PR stories directed to the general public.

In some cases the corporate executives have been successful -- especially in garnering the reckless pay practices that helped to fuel the 2008 crash.  It's really amazing to me, and unconscionable, that the SEC might consider not supporting disclosure of corporate pay disparities. Haven't we learned anything since 2008?

I am aware that you are under intense pressure by business interests to weaken or abandon the rule.  Those interests have been doing that for years -- and will continue. Do not give in. Instead,  please weigh your duty to protect investors and the American public against the self-interests of those seeking to undermine this rule.

Thank you for considering my comment,

Dory Storms

Baltimore, MD