Subject: File No. S7-07-13
From: Bryan Taylor

November 21, 2013

Dear Securities and Exchange Commission:

I am an investor in publicly traded companies through my retirement plan and personal savings including Microsoft (MSFT), Chesapeke (CHK), and a significant portion of my savings in S&P500 funds that include companies that are some of the most outlandish in terms of ratios.  Having worked in the executive suite of a fortune 200 this is the least the SEC should require -- leaving execs to give themselves pay increases while the company flounders or that dwarf what the vast majority of their workforce earns is wrong.  Assuming the earnings expected by the street are what they are, it allows a few obligarchs in a company to shift payroll to themselves from the hundreds of thousands of workers -- often without any visibility by the shareholders or board.

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.


Bryan Taylor

Clifton, VA