From: Todd Moore
Dear Securities and Exchange Commission,
I am writing to urge the Securities and Exchange Commission to act on its proposed rule making on executive compensation disclosure. Too often executives are richly rewarded even when their companies' performance is below par. Without better disclosure, shareholders, employees and the general public cannot evaluate whether executive pay packages are unjustly enriching executives at shareholder cost or providing fair compensation.
The newly proposed rules will make this crucial information more accessible to shareholders and the public. The new requirements to disclose total compensation figures, pensions and detailed compensation breakdowns will make it clear exactly how much top executives are earning and why.
I believe that CEO pay should be set by independent directors. Under the proposed rule, a director could secretly do $120,000 in business with a company, an amount that is more than four times the average worker's annual pay of $27,460. Shareholders should be told if directors have potential conflicts of interest, no matter what the amount.
I also urge the SEC to require that companies disclose pay-for-performance data. In order for investors to understand how pay and performance match up, companies need to explain more clearly what level of performance is necessary for a particular level of pay. I urge the SEC to require companies to disclose both the performance criteria and the performance targets they use when setting executive pay.
In my personal opinion, the way workers retirement packages are drying up, being sold out and eliminated is blatant abuse. These packages need to be guaranteed period. If the workers lose their retirement, so should the C.E.O. and other corporate officers. The Officers of corporations are workers too and if one worker loses his pension all workers should lose their pension. Fair is fair. I also encourage your Commission to make penalties stricter for mismanagement, fraud, double dealing, conflict of interest and all other illegal activities. Stricter penalties will make these thiefs think longer and or harder before committing crimes against America and its workers. It will also reduce the rampant Flock thinking that makes people think the chances of getting caught are lesser. The integrity of America's Companies is at stake. The stock market has suffered due to lack of investor confidence, and for good reason. Enron, World-com and dot bomb are household jokes. The real stories behind these various companies are not joking matters at all. I encourage a top down shake up of policies, procedures, penalties, personell, and provisions for compensatory regulation that will reduce corporate fraud, reinvigorate consumer confidence and bring a more level playing field to America's corporate game. The benefits will come in form of increased consumer confidence, increased worker productivity, increased stock prices, increased worker morale and countless other less tangible benefits. Please take this matter seriously, rein in these greedy C.E.O.'s and make life better in doing so.