Subject: File No. S7-07-13
From: TT Rosen
Affiliation: None

September 20, 2013

Eliminate excuse of "not material".

Include all forms of compensation/returns/etc. wired off-shore whether US Citizen, resident or other.

Include the smallest of offshore subsidiaries (not disclosed in financials because they are deemed not material -- hey, what's 20Mil but a drop in the bucket) because that is where hundreds of millions of fake profits(one big CR to liab or eq.) and losses(one big DR to fake asset) are "parked" in the "islands"/Caribbean, for 20 years then selectively brought to US (under radar, not "material")to offset gains/profits as they wish or disappear if not needed, selectively affecting amounts allocated to executive performance/compensation.