Subject: File No. S7-03-06
From: Delmar Newman, CFA
Affiliation: Private Client Investment Manager

September 5, 2006

Detailed, clearly presented spreadsheets enumerating highly compensated salaried employees compensation and termination packages are needed. Investors and anaylsts should have all the information for the 8 highest paid executives and probably for anyone whose current comp exceeds $1 mil. Many huge multinational companies employ over 100,000 people and in several companies there may be dozens of what most would consider "highly compensated" employees.

In addition, in this or other policy, I suggest that in any sale or merger of a public company that any special compensation paid to directors or highly paid executives be clearly disclosed immediately as a required component the announcement of the transaction's agreement.