"[T]he pay ratio rule should not be at the top of the SEC's agenda.... [B]ecause [the] pay ratio disclosures do not provide useful information about a company's operations, performance, or pay practices, such disclosures will be immaterial and, at worst, confusing to investors ... The SEC cannot ignore the very real and permanent compliance costs that the pay ratio rule will impose on all public companies.... Because the SEC has chosen to expend limited resources on the pay ratio rule, it is now significantly more difficult for the SEC to ... complete [other] mandatory rulemakings[.]"  MORE >>