Subject: File No. S7-07-13
From: B C Collins
Affiliation: Rolyan Fund

September 25, 2013

As manager of a small endowment where I commonly select equities, I have struggled with ways to assess CEO pay and how it should be factored among other fundamentals, such as revenue, profit growth, etc. The pay itself is disclosed, which is most appreciated. But there is no simple, quick way to judge whether it is appropriate. One can look at the size, but CEO pay has become so high, so unglued from what any person could actually need to live and raise a family,that this raw figure is without utility.
Comes now a clever proposition: Disclose the pay as a ratio of the median-paid employee. It is my fidiciary duty to choose the best stock for the lowest price. Now I can add "best priced" CEO I can see if the WalMart CEO's pay ratio is better than his counterpart at Target, etc.
Thank you, commissioners, for making my investment analysis a little more robust with such a simply device.

--B.C. Collins/The Rolyan Fund