Subject: File No. S7-07-13
From: Merry Foxworth

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 a CEO-to-worker pay ratio, as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act.

HOWEVER, this should be CEO-to-lowest-wage worker, NOT CEO-to-median-worker ratio. What meaning does median worker have? It needs to be the LOWEST PAID worker.

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.


Merry Foxworth

The Woodlands, TX