Comments on Proposed Rule: Pay Versus Performance

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Date Received
Date Letter Type Commenter Name
Meeting with SEC Officials Memorandum from the Office of Commissioner Michael S. Piwowar regarding a September 30, 2015, meeting with representatives of the Center on Executive Compensation
Meeting with SEC Officials Memorandum from the Division of Corporation Finance regarding an August 20, 2015, meeting with representatives of the Center on Executive Compensation
Meeting with SEC Officials Memorandum from the Office of Commissioner Luis A. Aguilar regarding an August 25, 2015, meeting with representatives of the Center on Executive Compensation
Public Comment Kim Jenett, Vice President, Human Resources, BorgWarner Inc.
Meeting with SEC Officials Memorandum from the Office of Commissioner Kara Stein regarding a July 30, 2015, meeting with representatives of the Ohio Public Employees Retirement System
Meeting with SEC Officials Memorandum from the Office of Commissioner Luis A. Aguilar regarding a July 30, 2015, meeting with representatives of OPERS
Public Comment Corporate Governance Coalition for Investor Value
Public Comment Roger Q. Doctor, New York, New York
Public Comment Dr. Richard C. Masterson
Public Comment James M. Cudahy, CAE, President and CEO, National Investor Relations Institute, Alexandria, Virginia
Public Comment Ken Daly, CEO, et al. National Association of Corporate Directors, Washington , District of Columbia
Public Comment Darla C. Stuckey, President and CEO, Society of Corporate Secretaries & Governance Professionals, New York, New York
Public Comment Stephen Scarpati and Eunsup Daniel Shim, Professors of Accounting, Jack Welch College ofBusiness, Sacred Heart University
Public Comment Tim Goodman, Hermes Equity Ownership Services
Public Comment Andy Restaino, Managing Director, Technical Compensation Advisors, Inc., Bellmore, New York
Public Comment Anne Simpson, Senior Portfolio Manager, Investments, and Director of Global Governance, California Public Employees' Retirement System Investment Office
Public Comment Avrohom Kess, Simpson Thacher & Bartlett LLP
Public Comment Bartlett Naylor, Financial Policy Advocate, Public Citizen, Washington, District of Columbia
Public Comment Cara Welch, Vice President of External Affairs and Practice Leadership, WorldatWork
Public Comment Catherine Cartier, President, Progressive Asset Management
Public Comment Christina Crooks, Director, Tax Policy, National Association of Manufacturers
Public Comment Christine P. Richards, Executive Vice President, General Counsel and Secretary, FedEx Corporation
Public Comment David N. Swinford, President and CEO, Pearl Meyer & Partners, New York, New York
Public Comment Donald G. Kalfen, Partner, Meridian Compensation Partners, LLC
Public Comment Edmund DiSanto, Executive Vice President, Chief Administrative Officer, General Counsel and Secretary, American Tower Corporation
Public Comment Eric Scroggins, Vice President, General Counsel & Secretary, Allison Transmission Holdings, Inc.
Public Comment Gregg H. Passin, Mercer LLC
Public Comment James Allen, CFA, Head, Capital Markets Policy, and Matt Orsagh, CFA, Director, Capital Markets Policy, CFA Institute
Public Comment Joanne M. Dahm and Michael Burke, Co-Presidents, et al., Aon Hewitt
Public Comment John Hayes, Chairman, President and Chief Executive Officer, Ball Corporation and Chair, Corporate Governance Committee, Business Roundtable, Washington, District of Columbia

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-07-15
Release Number
34-94074
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