Subject: File No. S7-07-13
From: Paul E. Sjordal

November 18, 2013

Dear Securities and Exchange Commission:

I am an investor in publicly traded companies with my Fidelity mutual funds/IRA and PNC annuities. The increase in inequality in the last 30 years has done severe damage to America and has fostered economic injustice and control of our government. Since the 1% hires lawyers to find ways to pay far less taxes than  working Americans do and reap far more wealth than they have earned, at the very least they should be required to disclose their corporations worker pay ratio.

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.

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.


Paul E. Sjordal

Naperville, IL