Subject: File No. S7-03-06
From: David L Spurr

March 28, 2006

I would also like to see included in executive compensation, all sources of compensation. All sources should not be limited to the company for which the executive works or serves, but should encompass all related and unrelated company businesses from which the executive derives compensation.

Many executives may have ownership interests in other businesses, companies or real estate trusts that may or may not be "related" to the company for which the CEO/Executive is employed.

It may or may not be possible for the executive to shift income from one business to another and to derive compensation from the "other" related/unrelated businesses.

It would be a significant improvement if it were possible to view an executive's compensation from ALL sources. This would provide analysts with additional information on where to look to see if income shifting was occuring. It would also provide better information on "related" party transactions that may not be occurring "at arm's length".

Disclosure should also include rental payments made by the company to real estate trusts that might have common ownership with company executives or board members. These rental payments may build equity in the r/e trusts or create a source of equity to borrow against for the executives. There should be a standard by which to measure whether or not the rental payments constitute "fair market" rent.