The Advisors' Blog

This blog features wisdom from respected compensation consultants and lawyers

December 4, 2013

Parsing the Pay Ratio Comments from Investors

Broc Romanek, CompensationStandards.com

Wow. The SEC has received over 105,000 pay ratio comments by its December 2nd deadline. Some interesting contributions, such as this joint letter from a bunch of Congress folks. And Sen. Menendez – the dude who inserted Section 953(b) into Dodd-Frank – got other Senators to sign onto his comment letter. In a cursory perusal, Dover Corp. is the only company I found to submit a comment letter with the math about its costs. Do you see others?

Here are some from institutional investors, most of which support the SEC’s rulemaking:

CII
ICCR
Illinois Teachers Retirement System
Hermes Equity Ownership Services
Walden Asset Management
Meketa Investment Group
RPMI Railpen Investments
Trillium Asset Management
AFSCME
PIRC, the largest proxy adviser in Europe:

Here’s a rebuttal of NIRI’s comment letter posted on the Huffington Post…