Subject: File No.
From: William J Barclay
Affiliation: Retired Sr VP, Chicago Stock Exchange

February 28, 2017

Dear Securities and Exchange Commission:

I am an investor in publicly traded companies through my retirement plan and personal savings.

I strongly support implementation of the CEO-to-median worker pay ratio disclosure rule as mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act.

This proposal should no longer be delayed.

(1) Pay ratio disclosure will help investors evaluate CEO pay levels when voting on executive compensation matters. The ratio of the CEO-to-worker pay is a valuable metric for investors, because it places CEO pay levels into a broader perspective.
(2) Investors such as myself may use pay ratios as a factor when casting say-on-pay votes. Pay ratio disclosure also will help investors better understand their companys overall compensation for all employees.
(3) High CEO-to-worker pay ratios can have a negative impact on employee morale and productivity. Disclosure of the pay ratios will help the capital markets better allocate capital to those companies that invest in their work forces.
(4) There is recent evidence that consumers are also interested in pay ratio disclosure - and will use it in determining where and how to make their purchases. Perhaps this is one of the reason that this proposal has been resisted.

I know there are those opposed to this increase in transparency. However, it seems to me that their primary arguments are wrong and ill-conceived. After all, if, as these opponents maintain, the very high compensation of CEOs is justified by their value added, then there should be no hesitancy to disclose. What, in fact I think we are seeing from opponents of disclosure, is the implicit recognition that these very high compensation levels are not, in fact, justified. All the more reason for the Commission to promptly implement this provision.

Dr. William Barclay
Oak Park, IL