March 29, 2006
Regarding your request for comment related to including a supplemental table for the "All Other Compensation" column, I believe that this should be a required disclosure. The idea behind the proposed changes to disclosure requirements for executive compensation is to increase transparency. Although, the amounts that make up the total value of the "All Other Compensation" column would be disclosed in the footnotes to the Summary Compensation Table, these amounts represent some of the more unknown types of compensation that executives receive and deserve increased visability. Therefore, they should be disclosed separately in a supplemental table with a total column that would tie into the Summary Compensation Table.
Sincerely,
Dan Ragsdale