6 pages. "[T]he approach suggested ... is overly prescriptive, and represents a troubling move away from the principles-based approach of many of the Commission's other recent compensation disclosure proposals, including, notably, the rule-making that led to the current CD&A format. We believe that a principles-based approach to the pay versus performance disclosure would provide companies with the flexibility necessary to communicate their pay for performance story more fulsomely, and beyond the use of one metric, and would enhance the benefit to shareholders of the proposed disclosure."  MORE >>