Subject: File No. S7-07-13
From: Larry Helming

November 17, 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 SEC’s rule 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 Board Members participation in compensation management of CEO pay level. The ratio of the CEO-to-worker pay is a valuable metric for investors, because it places CEO pay levels into a broader perspective.  Investors elect and vote on Board Members to run the company effectively.   Investors cannot manage the company except through the board members.  I would expand the SEC rule to disclose what the average CEO to Worker median was for all industries for the previous year for comparison purposes. 

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.


Larry Helming

Evansville, IN