Subject: Dodd-Frank Act Title IX: Executive Compensation
From: Gary Hays

September 18, 2013

The proposed rule in section 953 of Dodd-Frank requires reporting of the ratio between CEO compensation and employees' median pay. Such a rule is unnecessary and devoid of meaning. CEO pay in publicly held companies is now available in 10K reports, though the public will little understand the significance of reported compensation owing to treatment of stock options. Pay of CEO's varies by company size and industry, so comparisons between companies and across industries may be poorly understood. Median worker pay varies significantly across industries, thus ratios of CEO to median worker pay for a given company yields little useful information, unless the goal is merely to try to embarrass someone. Like so much of Dodd-Frank, the objective seems punitive.

Others have commented on CEO pay being out of control. Professional athlete pay is out of control. Hollywood celebrity pay is out of control. Government salaries are out of control. Just how will reporting spurious data change anything, and just what business has the government in addressing the market forces which result in such pay?