October 1, 2013
To Whom It May Concern -
I'm outraged that the Dodd-Frank regulations - and the pay ratio disclosure in particular - has taken so long to process. I recognize the difficulty in establishing rules consistent with the law's intent, but the slow-rolling is absurd. That the first pay ratio disclosures will not circulate until proxy statements is 2016 is an embarrassment and disrespectful to voters. As a corporate attorney at a national law firm that represents many public companies that will be subject to this new disclosure requirement, I can say this: it will not be difficult to implement this law. The complaints from commentators that you will be reading (likely regarding costs, time, and sensitivity to comply with this rule) are little more than stalling tactics from ashamed companies (and cash boons for their lawyers and accountants who are eager to over-complicate every new regulation).
My comment and request is to hurry up the process. At the very least, avoid further delays.