"Among all the possible changes the Commission could make to the proposed rule, dropping non-U.S. employees would by far save the most time and expense for multi-national companies, while dramatically increasing the relevance and potential value to investors by eliminating the distortions listed in the proposed rule.... We recommend that the proposed rule be revised to allow the issuer the option of making full-time equivalent adjustments for part-time employees and temporary or seasonal employee, to avoid an obvious apples-to-oranges comparison."  MORE >>