September 19, 2013
I have skimmed the 100+ pages of this new rule.
It is a good and valuable tool for investors to use in evaluating the company, their CEO AND THEIR PRIORITIES. My main concern is the fact that you have not limited the "wiggle room" sufficiently. Each company can make its own rules in deciding how to calculate the median employee compensation AND (from my reading of these rules) the Board and CEO can work the numbers of CEO compensation by using delayed compensation schemes to hide income and corporate obligations.
Make the rule clearer and include legal requirements for accurate calculation of median employee compensation AND include ALL compensation for CEO's.