Date: May 22, 2014

Issue: Pay Ratio

To: SEC

Filing Type: Regulatory

Description: The CCMC continues to believe that various mechanisms, such as roundtables and pilot programs, can be used to better inform the SEC of the problems and challenges that the Pay Ratio proposal poses to competition and capital formation, while not enhancing investor protection. Additionally, with estimated costs of over $700 million, the Pay Ratio proposal is an economically significant rulemaking and the CCMC requests that the SEC submit the Pay Ratio proposal to the Office of Information and Regulatory Affairs (“OIRA”) for an enhanced regulatory review process.

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