Subject: File No. S7-03-06
From: Richard J Gleeson
Affiliation: retired

February 18, 2006

This is in response to the following bullet on page 30.

Is the proposed change to Form 8-K to eliminate the delay in disclosing salary or bonus when they cannot be calculated as of the most recent practicable date appropriate?

Comment: If one cannot determine the total compensation in a timely manner then one cannot determine the total earning of the company in a timely manner and since for many smaller companies the pay of the executives significantly impacts the total earnings of the company at least a foot note should be added to form 10k to indicate that the current earnings are subject to revision because of executive compensation ambiguity. I would also propose that a grand total for column c be required and placed next to total earnings of the company on form 10k.