May 31, 2006
Dear Sir or Madam:
I respectfully request that the Securities and Exchange Commission act on its proposed rule for disclosure of executive compensation. Better disclosure would allow shareholders, employees and the general public a better opportunity to evaluate the fairness to all stakeholders of executive pay packages.
The proposed requirements to disclose total compensation figures, pensions and the details of compensation packages are important for understanding exactly how much senior executives are earning and the justification for that pay.
Executive pay should be set by truly independent directors. Furthermore, shareholders need to know when directors have any actual or potential conflict of interest.
Finally, I request that the SEC require companies to fully disclose their pay-for-performance contracts and results. Public investors need to understand the correlation of pay with performance (or lack of it). Therefore, the SEC should require that, when setting executive pay, companies reveal both their performance criteria and their performance targets.