The Advisors' Blog

This blog features wisdom from respected compensation consultants and lawyers

November 6, 2013

32,000 Pay Ratio Comment Letters So Far…

Broc Romanek, CompensationStandards.com

It’s still early – as most comment letters don’t get submitted until right before the deadline, which is December 2nd for this rulemaking – but the SEC already has received more than 32,000 comment letters on its pay ratio proposal, including roughly 20k using one form letter and another 8k using a second form, 3k using a third form and 1k using a fourth. Most of the form letters simply say they support Dodd-Frank’s Section 953(b). The others express more explicit support for the actual SEC proposal. So far, there haven’t been too many meetings with SEC Commissioners on this rulemaking – here’s that list.

My favorite one so far comes from a woman who claims she is with “Baker Schonchin Holdings Corporation,” a company that I couldn’t find via an online search:

We, at Baker Schonchin Holdings Corporation, believe it in our best interest, and that of our shareholders, employees, business partners, government affiliates, and customers, to willingly disclose payroll statistics, which include, but are not limited, to the following information: Name of Employee, Job Title, Yearly Salary, Department, City, State, Country, and any related pertinent details.

We strive towards a more transparent, ethical, and accountable business entity, so that we may present a more favorable corporate philosophy, but more importantly, that we are the # 1 leader, in moving forward, as a corporation, that refuses to do those practices, that are illegal, secret, or otherwise unsavory in nature. We strongly encourage our peers, to ensure that disclosure of salaries of all employees, is done so in a way that affirms the fair practices that are already in place, with respect to the vision, mission, and values of said company. Thank you.

I hope you noticed the initials of the company cited: “BS Holdings”…