Subject: File No. S7-07-13
From: Daniel Grossman

November 8, 2013

Dear Securities and Exchange Commission:

I am an investor in publicly traded companies through some direct stock holdings and mutual funds in my Roth IRA.

I am disgusted by how top executives are showered with cash, options, and golden parachutes while their employees must scramble to simply be "comfortable", and sometimes even that is too much to ask. There is no way an executive is "worth" 500x as much as one of his employees, period, and I want such information to be easily-accessible so I can better judge how I allocate my investments.

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.


Daniel Grossman