"[T]he Commission should give further consideration to the substantial economic costs and burdens that compliance with the proposed rule will impose on small businesses (in relation to their size) and weigh these against the unknown and unsupported benefits that compliance might provide.... [T]he usefulness of disclosure would be improved and the burden on employers would be lessened by the exclusion of part-time and seasonal workers from the pay ratio calculations .... If the Commission nevertheless determines that part-time and seasonal workers should be included, the Commission should take the logical step of permitting companies to annualize the compensation of such workers."  MORE >>