"As the Commission drafts its proposed rule, we ask that the following be incorporated. [1] Empower shareholder oversight of claw back practices by requiring that claw backs be disclosed.... [2] Require claw back of proportional incentive compensation where it is not numerically connected to financial results.... [3] Identify 'executive officers' as those provided under the SEC's Rule 16a-1(f).... [4] Identify the date triggering the three-year look back as the date of the first accounting misstatement."  MORE >>