SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed rules regarding proxy disclosure and solicitation enhancements, File No. S7-13-09. SIFMA comments in regards to the SEC’s proposed amendments to the rules regarding executive compensation proxy statement disclosure to be promulgated under the Securities Exchange Act of 1934, as amended (the Exchange Act), set forth in Release Nos. 33-9052; 34-60280 (the Proposal). We believe that reporting stock and option awards based on aggregate grant date fair value (as determined under Financial Accounting Standards Board (FASB) Statement of Financial Accounting Standards No. 123 (revised 2004) Share-Based Payment (FAS 123R) would provide investors with a clearer and more accurate understanding of total annual compensation for a company’s named executive officers (NEOs) and directors for all of the reasons cited by the SEC in the Proposal.