Subject: File No. S7-07-13
From: William E. Higgins

October 28, 2013

Dear Securities and Exchange Commission:

My first comment is an aside. I think companies that send jobs overseas should be penalized by not receiving the corporate tax breaks that they typically get.  Many Congressmen say, well we can't overtax the job creaters.  Well if they are job creators, maybe ok.  But let them prove where they are creating jobs.  If not, then tax them.

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.