Subject: File No. S7-07-13
From: Lowell Lehman

November 22, 2013

Dear Securities and Exchange Commission:

I am an American retired worker and an investor in publicly traded companies both 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.

This pay ratio disclosure will help investors like myself evaluate CEO pay levels when voting on executive compensation matters. I realize that by myself I have little leverage, but if enough other investors, large & small, know these obscene pay ratios, perhaps some pressure can be brought to bear. As difficult as it is to get a decent return on investments, it is ridiculous for companies to compensate CEO's and other high-ranking executives the way they do.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.
As it currently stands, worker pay is dropping, while CEO pay is going out of sight. How many workers could be hired for a year with what a CEO makes in one month? The current ratio of 350 or so to one means that a CEO makes as much in about one day as his average worker makes in a whole year!

I urge you to adopt the rule as proposed.

Sincerely, Lowell Lehman