October 4, 2013
My comment is pretty basic. The proposed regulations allow corporations to decide for themselves what is compensation and what isn't, or in other words to decide how much they want to admit to paying their CEOs and employees and then cook up some accounting tricks to make it look that way,and to decide for themselves what subset of their employees to actually count when calculating the median, or in other words, to decide what the median compensation is and then cook up some spurious "data" to justify their claim. We don't need a federal regulation to require companies to tell us whatever they feel like telling us, true or not, about the ratio of their CEO's compensation to the compensation of their median employee. They're already doing that voluntarily. Please fire whoever was in charge of getting this written, and go back and write an actual regulation.