May 13, 2006
Dear Sirs,
Again we see a regulatory agency destroying the very market it ostensilby intends to protect. The equity markets and the companies participating in them die by a thousand tiny cuts of regulatory interference. The equity markets in the USA are strong not because of the SEC, but in SPITE of it. Imagine the earnings and liquidity of the markets without the burden of regulatory interference.
This new proposed rule will have far reaching effects will outside the scope of both prudent regulatory interference in the market and is well outside the scope of any reasonable contruction of legislative intent.
Disclosure of the details of highly-paid employees who are not 'insiders' in no way benefits 'investors'. It will however destroy a company's ability to attract talent, create new dislcosure burdens and costs, and force companies to avoid disclosure by paying new talent 'off the books'. Your agency is about to destroy yet another tiny portion of the marketplace.
Presumably, the purpose of this disclosure is to enhance the ability of an prospective investor to make an 'informed' decision. Any prospective investor is well aware of talent salary information in general form already and they are also well aware of the fact the details are NOT disclosed. This fact means the investor is absolutely fully informed and assumes any risk associated with a purchase of stock under those conditions.
This rule, as ALL regulatory actions, will create or amplify the very 'problem' it is designed to eliminate.