Subject: File No. CLL-15
From: David Kritz

I am writing on my own behalf to propose a limited modification to the executive compensation disclosure rules. This change would improve the usefulness of the disclosures, focus attention on material information, and reduce the risk of errors. Specifically, I recommend that all amounts reported in the Summary Compensation Table be rounded to the nearest $1,000. For purposes of executive compensation disclosure, amounts below $1,000 are not material and do not meaningfully enhance investors' understanding of total compensation. This simple change would: - Simplify the collection and reporting of data for the Summary Compensation Table; and - Reduce the likelihood of errors in the totals reported for each named executive officer. The SEC might consider a similar modification for other compensation disclosures, such as for the "Compensation Actually Paid" in the Pay Versus Performance disclosure, the "Options Exercised/Stock Vested" table, etc. Thank you for your consideration of this suggestion.