Subject: File No. S7-07-13
From: Chuck Steele

October 26, 2013

Dear Securities and Exchange Commission:

Transparency gives people not only necessary information, but also context for making important decisions. Our success and longevity as a society are dependent on this sort of transparency. The only reason to oppose it would be to keep people uniformed, which only benefits the powerful.

I am an investor in publicly traded companies through my retirement plan and personal savings.

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.


Chuck Steele