Subject: File No. S7-03-06
From: Jana F. Reidy
Affiliation: Product Manager, Standard and Poor's

February 24, 2006

I think just about everyone will agree that executive compensation disclosure needs to be revamped, and so I think you'll see very strong support for this proposal. However, part of this 370-page proposal also calls for the elimination of the proxy Performance Graph. I have to wonder how many people really are in favor of that.

To eliminate the proxy Performance Graph would be a great disservice to all shareholders and potential investors. On the first page of the proposal it is made clear that a main objective of this rule change would be to provide data in "plain English" and to "provide investors with a clearer and more complete picture". I can't imagine a more clear and complete way to illustrate the value of a company than the Performance Graph.

The Performance Graph is a concise snapshot of how the company is performing amongst its peers and relevant indexes. And, contrary to what this proposal states, total return data is not readily available on the Internet. What is widely available is pricing information, but that does not include any reinvestment of dividends and isn't a true indicator of the value of the company.

If we were honest, how many of us really read every paragraph of the proxy statement and how many go straight for the graph to get a clear picture of how a company is doing? The Performance Graph is for the common, everyday investor, and eliminating it would be taking away the average persons window into the corporate world.