Subject: File No. S7-07-13
From: Tom Wilson

October 25, 2013

Dear Securities and Exchange Commission:

I am an American worker and an investor in publicly traded companies through my retirement plan and personal savings.

I strongly support the United States Security & Exchange Commission’s proposal to require publicly traded companies to disclose the CEO-to-median worker pay ratio.  The ratio disclosure is mandated in 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 tool for investors in evaluating and voting on CEO pay; scrutinizing the performance of Boards of Directors; and, identifying possible investment risks. 

I believe CEO pay must be put into perspective with pay levels throughout a company’s employees.  Lopsided CEO-to-worker pay ratios can harm morale and productivity among a company’s workforce.  This disclosure may help capital markets become more efficient in allocating resources to the companies that re-invest in their workers.

The fact of the matter is that these CEO’s are accepting these untoward recompense under somewhat false pretenses. None of them are founders or original stockholders or even the controlling stockholders in a closely-held family corporations, but hired helps brought in to conserve an on-going operation. They are paying themselves as if they were originally exposed to the entrepreneurial risks of a start-up, but they  are not Bill Gates or even Warren Buffet or Elon Musk. And, once they go public, their risk burden has been shifted unto a larger investment pool which expects prudent operational policy to ensure their sustained ROI. The fact is that most of these CEOs are stripping assets and raiding payrolls in the name of cost savings and then paying themselves what amounts to usury on monies they looted from the fiscal blood stream of the corporation. It is a strategy of systematic theft, Frank Lorenzo’s rape of Eastern Airline being the archetype for the business model.

I urge you to adopt the rule as proposed.


Tom Wilson