May 4, 2015
As a CFO of a public company, The Dixie Group, Inc., I am discouraged that the proposed rule adds two new burdens to the proxy process. The definition of "actual pay" will be distorted by time periods of when payment is made. We grant a portion of compensation as a long term incentive and is paid when the executive turns 60. Therefore, an executive can accrue 20 or 25 years of stock grants and they are all paid at one time when they turn 60. This will tend to distort the year when actually received. The second issue is having to XBRL tag the proxy. When we went from block tagging the financial statements to detail tagging we went from a 1 day process to a 5 day process. It is a totally useless exercise and requires that every date and number be tagged. A simple block tag is quick and easy. Even in our financial statements, the prescribed tags for the income statement and balance sheet change each year as we keep having to adopt a whole new taxonomy. Plus I cannot find a single investment firm that has ever used the data.