Mar. 18, 2022
Gary Gensler, Chair SEC Headquarters 100 F Street, NE Washington, DC 20549 Vanessa A. Countryman Secretary, Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 Re: Reopening of Comment Period for Pay Versus Performance (File No: S7-07-15) Dear Chairman and Secretary: AFREF sent a letter commenting on the Security and Exchange Commission's proposed rule to implement Section 953(a) of the Dodd-Frank Wall Street Reform and Consumer Protection Act, relating to executive compensation for financial performance. The letter welcomes the SEC's implementation of this important provision and makes recommendations to minimize executives' incentives to focus on short-term shareholder returns at the expense of longer-term investments that contribute to equitable and sustainable economic growth over time. Please consider the recommendations offered in the letter to make the rule as effective as possible at facilitating informed shareholder pay for performance voting, while avoiding incentivizing risky behavior and fostering inequality. Re: Full letter: https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-bf64695e4e779733&q=1&e=d60825b4-383f-4113-bd60-1d116b25c68d&u=https%3A%2F%2Fourfinancialsecurity.org%2Fwp-content%2Fuploads%2F2022%2F03%2F3.18.22-corporate-governance-AFREF-pay-for-performance-comment-letter.pdf Yours sincerely. Robert E. Rutkowski cc: Legislative Correspondence Team 1705 Longworth House Office Building Washington DC 20515 Office: Fax: 2527 Faxon Court Topeka, Kansas 66605-2086 P/F: E-mail: