November 7, 2013
Dear Securities and Exchange Commission:
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.
All too often when a company hits the skids workers get the pink slip, but CEO's who were often most responsible for the company going belly up get a golden parachute.
Disclosure of top executive pay is a first step, but with so many of these top execs getting stock options, calculating the pay of those on top is only a guesstimate at best.
Still, I strongly support the reporting of pay on SEC regulated companies and in the future large privately held companies like Cargill and Archer Daniels Midland because of their size and them being in the food and grain business should be subject to the same regulations as well. Thank you
Sincerely,
Karl Meller
Minneapolis, MN