August 31, 2016
The proposal in section 17 calls for elimination of the equity compensation plan information table. While we agree that disaggregation of information between equity compensation plans approved by security holders and those not approved by security holders is no longer necessary given the shareholder approval requirements of major national securities exchanges, we believe the information provided in the table is still necessary on an aggregated basis. This is because there is no other place in GAAP or SEC disclosure rules that requires the specific disclosure of the number of securities remaining available for future issuance. Please refer to the table in section B of the adopting release of the equity compensation plan information table Release Nos. 33-8048, 34-45189 File No. S7-04-01. We respectfully request that you retain this tabular disclosure on an aggregated basis.