Comments on Subtitle E of Title IX–Accountability and Executive Compensation under the Dodd-Frank Wall Street Reform and Consumer Protection Act

We are submitting this letter in response to the solicitation by the Securities and Exchange Commission (the “Commission”) for preliminary comments on Subtitle E of Title IX–Accountability and Executive Compensation of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). Set forth below are several recommendations we ask that the Commission consider in proposing rules to implement the relevant sections of the Act.