December 28, 2006
Please immediately reverse your decision to revise EXECUTIVE COMPENSATION DISCLOSURE as published on 22 December 2006.
As a substantial shareholder I had welcomed the original proposed rule to disclose the total value of option and restricted stock awards WHEN GRANTED rather than "over the service period" as you have amended. Companies can use NOTES to document the service period spread if they feel this better informs other shareholders, but keep grant date disclosure for me and all shareholders (most) like me.
I regard your statement that
"The amendments are intended to provide investors with more complete and useful disclosure about executive compensation. Disclosing the compensation cost of stock and option awards over the requisite service period will give investors a better idea of the compensation earned by an executive or director during a particular reporting period..."
as badly misguided - it does not meet my needs I wish to make decisions on which stocks to sell, based on whose boards overcompensate - your action makes my decision MUCH harder.
Once again, PLEASE REVERSE THIS DECISION
Thank you for your time.