The Advisors' Blog

– 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…