Subject: File No. S7-07-13
From: Wes Bullock

October 27, 2013

Dear Securities and Exchange Commission:

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

According to the book, "Coming Apart", by Charles Murray, CEO pay has, adjusted for inflation, risen from $1M in 1970 to $16M in 2006. In his book, he calls this situation "unseemly". I have another term for it but won't use it in polite company. Is their job actually that more difficult today than in 1970?

I work in a position without the benefit of a union to enforce fairness. My employer uses "performance appraisals" and "market based compensation models" to ensure I'm not paid a dime more than they think I'm worth to the company. It's time we do the same for these guys.

A good first step in this direction is to require them to turn on the lights and let us see the ratio of CEO pay to that of the average employee.

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. Why do we have a law that isn't being enforced?

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.

We also have given too much power to those who run mutual funds, and other investment instruments, in deciding CEO pay. We need to find a way to force these funds to listen to the voice of the investors who are depending on the stock market to retire. Remember, most companies are doing away with pension plans and moving to 401ks. We can't manage our retirement funds if we have no voice into who runs the companies we've invested in and how much they get paid considering what they've done on behalf of the stock holders.

Also, I've done an extensive study of the makeup of the Boards for the companies comprising the Business Roundtable lobby group. These are the CEOs of the companies who won't hire anyone over 50 years old (except for upper level executives and board members) , but they recommend to the Congress and the President that the minimum age for Social Security be raised to 70 years old. This may be necessary to save Social Security but I don't want to hear it from them because they won't hire older people. At least 90% of Board Members of Business Roundtable companies are currently CEOs of other large companies or former CEOs of other large companies. I think that is the root of the problem we're seeing.

In fact, I've seen one company, Blackstone, which went public and issued an IPO a couple of years ago, but the CEO still sets his own compensation. Their rationale can be found in their 2012 proxy statement. See p 215 of the following link:
How does the SEC allow this to continue?


Wes Bullock

Keller, TX