Subject: File No. S7-07-13
From: Bren Ames

December 2, 2013

I support Dodd-Frank rule 953(b), which strikes me as being all about the intersection of pay equity and investor value.

American workers are more productive than ever, but, year after year, studies show working Americans earning less and less, even as CEO pay balloons and corporate profits soar.


In addition to receiving massive compensation and retirement packages, CEO lifestyles are almost always subsidized by the public.  Executive compensation AND public subsidies should be transparent. 

Land and resources are provided for only a fraction of their market value to the wealthy for development.  Tax credits and other public subsidies are offered in exchange for 'jobs' - but these are often temporary, part-time, and less-than living wage positions, and in order to survive even full-time workers must draw upon public assistance to meet basic needs.  Underpaying workers yields the temporary illusion of profitability, enabling executives to drain wealth from the community and the corporation.

Executives benefit from decisions to underfund corporate pension plans - making the company appear to be more profitable - inflating the stock value and executive bonuses.  But when the pension later fails, workers, like my father, are told 'too bad, we can't afford to pay you that pension that you PAID FOR WITH DEFERRED EARNINGS', and we're cancelling that health insurance policy that you were relying on for care in your old age.'   Then the worker who WORKED and planned and saved for retirement is left reliant on the safety net of Social Security, Medicare, maybe food stamps, and maybe the Pension Benefit Guarantee Corporation.  And the executive has been subsidized - again.

Unjustified waivers of liability are often awarded to corporations and their executives,  shifting risks and costs to the public.  Fines for misconduct and harm to the public and the environment are often tax deductible (subsidized).

Despite the well-established fact that their conduct caused great harm to taxpayers and the American economy, $7 billion of JP Morgan's settlement is tax-deductible - thanks to part of the tax code that states costs associated with corporate legal cases can be treated similarly to a company’s wages or equipment expenses.  Taxpayer subsidy in this case extends far beyond the tax deduction, beyond the many who lost their homes and their jobs.  Many of us have lost most or all of the equity in our homes and our retirement savings.  Ongoing, generational taxpayer subsidy to Wall Street executives. Meanwhile, the CEO of JPMorgan Chase, Jamie Dimon, received $18.7 million in compensation last year

Disclosing corporate pay ratios between CEOs and average employees will finally show which corporations are driving this trend, which siphons money away from investors, and into the pockets of CEOs. In 1990, senior executive pay absorbed 5 percent of corporate profits. Today, according to Government Metrics International, it absorbs 10 percent.

Fairer pay structures mean stronger companies and a stronger economy – both of which are important to me as a consumer and as an investor.

No doubt there are a select few who benefit from the status quo of keeping the pay disparities undisclosed. But you must protect the American public, not the interests of CEO executives.

I urge you to stand firm and implement a strong rule that will uphold the intent of the Dodd-Frank law.

Thank you for considering my comment,

Bren Ames

Gainesville, GA