NBAA’s was one of more than 170 comments filed (mostly in support) to the Securities and Exchange Commission rulemaking proposal to require more detailed reporting of top executive compensation, including such perks as personal use of corporate aircraft. While the SEC’s 370-page NPRM addressed a wide variety of proposed regulations, NBAA’s comments were limited to the agency’s request for information with respect to the valuation of perquisites and other personal benefits such as personal use of employer-provided aircraft. NBAA said it “agreed with the SEC’s assessment that the current standard of reporting perquisites and other personal benefits, aggregate incremental cost, is the proper valuation methodology.” The association also elaborated on why aggregate incremental cost is the right methodology and said, “No other mechanism reports the true cost to the company of providing such benefits, which is the information that shareholders need to know.”