Subject: File No. S7-07-13
From: Floyd Sipe

November 21, 2013

Dear Securities and Exchange Commission:

America is in the next Guilded Age. We are quickly turning into a society of the "Haves" and "Have Nots." Do you think the Haves are going to ever say, "I have enough"? If I could use professional sports as an analogy, the answer is "no". To exacerbate the problem, CEOs handpick their boards and even though I may be a shareholder, I have zero control over how much the CEO is paid v the workforce that keeps the wheels in motion. I have been self-employed for 8 years so I understand the meaning of working hard and deserving everything I earn. When a client pays me for my services they expect something in return. When my investment dollars go to a company I want the company under his/her watch to share that wealth with everyone working for that company, and not purchase another yacht or vacation home while the crime rates and poverty increase all around me.

When the tide rises, all ships should rise.

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.


Floyd Sipe

Cambridge, MA