Subject: s7-07-13 comments
From: Leigh Henderson

March 31, 2017

The website of the U.S. Securities and Exchange Commission states "The laws and rules that govern the securities industry in the United States derive from a simple and straightforward concept: all investors, whether large institutions or private individuals, should have access to certain basic facts about an investment. ...  To achieve this, the SEC requires public companies to disclose meaningful financial and other information to the public."

Apparently the apportionment of a company' profits is not considered meaningful. Excessive CEO pay, be it in cash or securities, means less investment in both new-product development and in attracting and retaining a stable, experienced workforce. As an investor, I believe this corporate strategy is fatally flawed and that such a company is not safe for a long-term investment.

    The SEC has earned a reputation as the fox guarding the henhouse. Its refusal to enact the Dodd-Frank Law requiring that public companies disclose information comparing CEO compensation to median workforce compensation simply reinforces that perception.

Leigh Henderson

MD