April 10, 2006
To Whom It May Concern:
I think the SECs recommendation to take away the total return chart completely from the proxy is nuts. If one of the objectives of the SEC is clearly defined performance for shareholders then a companys total return chart is without question the best resource we have for this. The total return chart is the only piece of information in the proxy that lets investors see what the company has produced for them by way of financial results. It is the only means we shareholders have to measure managements comparative performance in relation to others in a peer group of companies and the market.
I think the SEC should require plain text discussion evaluating any changes in executive compensation with total return to shareholders. The total return chart is the only way investors have to measure any changes to managements remuneration and it is the only way shareholders have of justifying any raises. Stockholder total return provides an important perspective to reasonably assess managements compensation, and without it there is no balance to the discussion of remuneration. If management delivers for us, there is not much to complain about?
Total return information is not available for free by a great number of individual investors. The notion that the total return chart now presented in the executive compensation section of the proxy can be easily found on the internet is incorrect. Anything involving the internet has a great opportunity for misuse. Apart from the charts availability on the internet, it should still be included in in the proxy for the ease of investors and to make sure all the comparisons linking total return and executive compensation are correct.
Thank you for the chance to respond,
David Carlen Maddux, Sr.