Subject: File No. S7-07-13
From: Bonnie Overcott

January 4, 2014

Dear Securities and Exchange Commission:

I am an investor in publicly traded companies through my retirement plan and personal savings.  With millions of Americans counting on their investments for retirement, we need more control over the excessive amounts of money executives pull out of these companies and must be sure they are not creating short term gains at the expense of the long term health of the corporation.

I strongly support the SEC’s proposal requiring companies to disclose the CEO-to-median worker pay ratio, as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Pay ratio disclosure will help investors evaluate CEO pay levels when voting on executive compensation matters. The ratio of the CEO-to-worker pay is a valuable metric for investors, because it places CEO pay levels into a broader perspective.

For example, investors may use pay ratios as a factor when casting say-on-pay votes. Pay ratio disclosure also will help investors better understand their company’s overall compensation for all employees.

High CEO-to-worker pay ratios can have a negative impact on employee morale and productivity. Disclosure of the pay ratios will help the capital markets better allocate capital to those companies that invest in their workforces.


Bonnie Overcott

Minneapolis, MN