Subject: File No.
From: Bill Korn
Affiliation: CFO, Medical Transcription Billing, Corp. (Nasdaq: MTBC)

February 7, 2017

I have no problem with the rule for larger, more mature public companies, but I think it should be discretionary for JOBS Act Emerging Growth companies.

For many Emerging Growth companies, annual pay for the CEO is very lumpy. Often there is below-market rate pay prior to an IPO, and depending on the direction of the stock after the IPO, there may be a windfall, or if shares fall, net pay may effectively be negative.

Reporting ratio of the value of a component of pay for a single year to the lower-paid employees may dramatically overstate or understate the true value. Absent a full CDA disclosure, reporting this in isolation might give a very misleading view of pay.


Bill Korn