Subject: File No. S7-07-13
From: Roger Kofler

October 28, 2013

Dear Securities and Exchange Commission:

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

I strongly support the United States Security & Exchange Commission’s proposal to require publicly traded companies to disclose the CEO-to-median worker pay ratio.  The ratio disclosure is mandated in 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 tool for investors in evaluating and voting on CEO pay; scrutinizing the performance of Boards of Directors; and, identifying possible investment risks. 

I believe CEO pay must be put into perspective with pay levels throughout a company’s employees.  Lopsided CEO-to-worker pay ratios can harm morale and productivity among a company’s workforce.  This disclosure may help capital markets become more efficient in allocating resources to the companies that re-invest in their workers.

I urge you to adopt the rule as proposed.


Roger Kofler