Subject: File No. S7-07-13
From: Richard Baerlocher

October 22, 2013

Dear Securities and Exchange Commission:

I am a retired government worker and through the retirementannuity  and personal savings I have learned to watch CEO compensation..

I strongly support the SEC’s proposal requiring companies to disclose the CEO-to-median worker pay ratio, as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act.

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.

For example, investors may use pay ratios as a factor when casting say-on-pay votes. Pay ratio disclosure also will help investors better understand their company’s overall compensation for all employees.

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 workforces.

CEO and senior management salaries are rolled into the compensation figures for publicly traded companies.  These figures will show that the production workers are not the reason the corporate costs are so high, but the cost of excessive management.  When the management is overpaid they will not care about the product or the employee welfare, and cause major problems within the corporation.  Stock benefits also need to be cut to maximum 5 percent of annual salary!


Richard Baerlocher

Portland, OR