Subject: Comment on File Number S7-07-13

October 12, 2013

I support Dodd-Frank rule 953(b), which strikes me as being all about the intersection of pay equity and investor value.

American workers are more productive than ever, but, year after year, studies show working Americans earning less and less, even as CEO pay balloons and corporate profits soar.

Disclosing corporate pay ratios between CEOs and average employees will finally show which corporations are driving this trend, which siphons money away from investors, and into the pockets of CEOs. In 1990, senior executive pay absorbed 5 percent of corporate profits. Today, according to Government Metrics International, it absorbs 10 percent.

Investing more in higher pay for workers than in higher pay for already overpaid executives produces a bigger return, since (1) workers who feel appreciated (and that BEGINS, but does not end, with a fair paycheck) are less likely to grumble while waiting for better opportunities, and less likely to bolt when one does come along, and (2) higher pay is more likely to attract the "strivers" rather than the "settlers."

And investors choosing which stock to buy have a right to know this information, because it is as relevant as, and possibly more relevant than, information about pending lawsuits, patents held by the company, and other factors that are already listed in the annual report and prospectus of publicly held companies.

Fairer pay structures mean stronger companies and a stronger economy – both of which are important to me as a consumer and as an investor.

No doubt there are a select few who benefit from the status quo of keeping the pay disparities undisclosed. Stand firm, and implement the law as written.

Thank you for considering my comment,

Allan Richardson

Marietta, GA