Subject: File No. S7-07-13
From: Virginia Fischer, JD

October 3, 2013

The rules, as proposed, are a meaningless exercise. They do not require disclosure of total compensation paid to executives, nor do they outline the methodology to be used to make comparisons between executive pay and the rank-and-file's compensation. So any information that is provided by those companies will be useless, to regulators, investors, and to the public.

For some unknown reason, the SEC is worried about the cost involved to the companies in reporting this information - all of which is already kept by most corporations, and certainly by all public corporations. So their expenses in producing a report which identifies an executive's total compensation, including deferred and in-kind compensation, and which compares that to a weighted average of employees' compensation (which should include the compensation of any temporary workers or independent contractors) are very little more than analyzing data that they routinely develop for their own use. That is not a significant burden, but is necessary for regulators, investors and the public to make meaningful comparisons.