Subject: File No.
From: David Blitzer

March 24, 2017

This is an important rule and it needs to be implemented and enforced. President Trump himself, in his campaign, denounced outrageous CEO pay, so it would be hypocritical if his Administration undermined CEO pay transparency. Additionally, I don't view this disclosure as adding any undue burdens. All companies maintain salary information on all employees. I believe the following steps would allow a company to calculate this information.

Export all salary information to Microsoft Excel or the free software Google Sheets.

Remove the CEO's salary from the list and put in the next column over.

At the bottom of the column of salaries, enter the following formula:

=Median(A2:A50) Edit the range in the parenthesis to include the entire salary column.

Hit Enter.

Divide the result of the median function by the CEO's salary.

Disclose this ratio publicly in existing financial disclosure statements.

For a small company, this would take about 10 minutes. For an extremely large company it would take about 30-60 minutes.