Subject: File No. S7-07-15

July 6, 2015

Progressive Asset Management has long advocated for increased transparency concerning the growing problem of skyrocketing executive pay, and we applaud the proposed SEC Pay for Performance rules.  While not perfect, the rules go a long way in helping shareholders and citizens to evaluate whether executive pay and bonuses are truly justified based on a corporation’s financial performance.  It’s important to note that the proposed rules would implement a requirement mandated by the Dodd-Frank Act.  We believe they would help level the playing field for both companies and investors, and allow shareholders to be better informed when they vote to elect directors and approve executive compensation.


Catherine Cartier
Progressive Asset Management
1814 Franklin Street, Suite 503
Oakland CA 94612