Date: June 30, 2015
Issue: Regulatory Reform
To: Brent Fields, Secretary, U.S. Securities and Exchange Commission
Filing Type: Regulatory
Description: The CCMC believes that a Pay Versus Performance disclosure can assist investor decision making, but the Proposal fails to do so. The Proposal in its current form will increase the complexity of disclosures—counter to the SEC’s current efforts to promote disclosure effectiveness—fails to provide investors with decision useful information on compensation or performance and may incentivize short-termism.