Subject: File No. DF Title IX - Executive Compensation
From: Daniel Roberts

October 26, 2010

Sir, Madam,

Reporting of Executive Compensation is a great idea, and is not new. It is mandatory in the UK, India, New Zealand and a number of other countries. Of course, so is a range of business information in the form of annual reports and reports to regulators and exchanges. It would be great to see the SEC require executive compensation well beyond the narrow requirements of Dodd-Frank.

Currently the SEC required the provision of regular filings (10K, 10Q, 20F) in the XBRL format - to enable the rapid consumption of reported information at the data element level. Soon every filer will be required to provide individually tagged data elements for all numeric values in their quarterly and annual filing.

I hope the SEC's final rule to meet the Dodd-Frank legislation will require that CEO compensation (and any other compensation for that matter) be provided in the same data format as the quarterly and annual filings. If CEO compensation is not required in the XBRL format, this will mean that analysts and consumers of the information will still need to manually find this information and copy/paste or re-key the information.

The SEC should take the extra step and require the information to be provided in XBRL (or what the SEC calls "interactive data").

Kind regards,
Danel Roberts