Comment Letter on the SEC's December 2006 Amendments to the Proxy Disclosure Rules

This letter sets out our comments and suggestions regarding the SEC's interim final proxy disclosure rules released December 22, 2006 that amended the final proxy disclosure rules released in August 2006. Additionally, we provide comments on: reporting of changes in the aggregate pension value in the Summary Compensation Table; reporting of equity awards in the Nonqualified Deferred Compensation Table; and, the proposed rule to require the disclosure of the position and total compensation of up to three additional non-executive employees who have significant policy making authority.

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