November 15, 2013
I am writing to express strong support for the U.S. Securities and Exchange Commissions proposal requiring disclosure of the CEO-to-worker pay ratio as mandated by Section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
The ratio of CEO to worker pay at individual companies is critical, material information for investors. Significant pay disparities inside a company can harm both employee morale and productivity and can detract from the firms overall performance. Disclosure of the median employee pay will help investors better understand companies overall compensation approach to developing their human capital, the economists term for the aggregate competencies of labor that yields financial value.
As required by Dodd-Frank Section 953(b), the proposed rule appropriately requires companies to disclose the median pay of all of their employees. Given recent labor market trends, many publicly traded companies employ a majority of international employees or part-time employees. Investors would receive an incomplete picture of their companys pay practices if these employees were excluded from the disclosure.