Subject: Dodd Frank CEO Pay Ratio legislation
From: Nicole Schmidt
Affiliation: A.O. Smith Corporation

September 11, 2017


We are running into significant challenges in gathering base wages, incentives/bonus earned and temporary help pay information from all of our US and especially global offices.   We have a large population outside of the US who work as production/assembly.     The inclusion of global production workers significantly impacts our pay ratio compared to US companies.  

How are other global companies gathering this information?   Has there been any consideration to revise the ruling for the 2017 proxy reporting?

Please advise at your earliest convenience.

Thank you,


Nicole Schmidt
Global Compensation Manager
A.O. Smith Corporation
11270 West Park Place, Suite 170
Milwaukee, WI 53224