Matthew Bieberly
ComstockAbout Matthew Bieberly
Matthew J. Bieberly, age 45, is Comstock Inc.’s Chief Accounting Officer; he joined as Director of SEC Reporting & Disclosure in January 2023 and was promoted to Chief Accounting Officer in November 2023. He previously served as Director of Corporate Accounting & SEC Reporting at ONE Gas, Inc., and is a Kansas State University graduate (B.S. in Accounting and Finance; Masters of Accountancy) and a certified public accountant . During his tenure, Comstock reported total shareholder return increases of 85.8% in 2023 and 41.3% in 2024, while FY2024 net loss was $53.4 million, framing the company’s pay-versus-performance context .
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| Comstock Inc. | Chief Accounting Officer (Principal Accounting Officer) | Nov 2023–present | Principal accounting officer for SEC reporting; signatory on 10-K/10-Q certifications |
| Comstock Inc. | Director of SEC Reporting & Disclosure | Jan 2023–Nov 2023 | Led SEC reporting and disclosure processes |
| DWC CPAs and Advisors | Manager | 2021–2022 | Public-company accounting experience |
| ONE Gas, Inc. | Director SEC Reporting & Corporate Accounting | 2016–2021 | Oversaw SEC reporting and corporate accounting |
External Roles
No public-company directorships or external board roles for Bieberly are identified in Comstock’s FY2024 10-K executive officer section or the 2025 proxy .
Fixed Compensation
| Year | Base Salary (USD) |
|---|---|
| 2023 | $175,000 |
Note: Bieberly was appointed Principal Accounting Officer on November 9, 2023, with a disclosed annual salary of $175,000; subsequent salary and cash bonus details are not disclosed in filed materials .
Performance Compensation
| Incentive Element | Design | Target | Actual/Payout | Notes |
|---|---|---|---|---|
| Company executive performance bonus framework | Performance-only bonuses; opportunity up to 100% of base salary (as set under 2022–2024 plan) | Up to 100% of salary | 2024: No bonuses paid to named executive officers | CAO-specific bonus outcomes not disclosed; program indicates cash-at-risk focus |
| Equity awards (recent 3 years) | Company disclosure indicates no new stock-based compensation granted during past three years; ~99% of exec compensation was base salary and some performance bonuses | n/a | n/a | CAO not in NEO table; equity grants for CAO not presented in proxy |
Equity Ownership & Alignment
- Stock options: Previously granted 30,000 options under the equity plan (strike price, vesting schedule, and expiration not disclosed) .
- Beneficial ownership: The 2025 proxy’s beneficial ownership table lists directors and named executive officers; Bieberly is not included individually, and his specific beneficial holdings are not disclosed. Directors and executive officers as a group owned 1,206,162 shares (4.5%) based on 26,903,872 shares outstanding as of March 25, 2025 .
- Trading policy: Company policy prohibits hedging, short sales, and similar techniques for directors, officers, and employees .
- Ownership guidelines and pledging: No CAO-specific stock ownership guideline compliance or pledging disclosures were identified in the extracted filings .
Employment Terms
| Term | Detail |
|---|---|
| Appointment date | Appointed Principal Accounting Officer on November 9, 2023; serves as Chief Accounting Officer |
| Role scope | Principal Accounting Officer; signatory on periodic reports |
| Base salary | $175,000 (as of appointment) |
| Contract term / severance / change-of-control | Not disclosed in filings reviewed for CAO |
| Non-compete / non-solicit / garden leave | Not disclosed in filings reviewed |
| Clawback / recovery | Company includes a Compensation Recovery Policy section in proxy; specific CAO applications not detailed in excerpts |
| Securities/trading | Hedging and short selling prohibited; policy applies to officers |
Performance & Company Context
| Metric | 2023 | 2024 |
|---|---|---|
| Total Shareholder Return (Value of initial fixed $100 investment) | $190 | $140 |
| Net Income (Loss) | $10,526,252 | $(53,402,898) |
Note: Company-wide figures contextualize the environment during Bieberly’s tenure; he served as CAO beginning November 2023 and signed FY2024 and 2025 quarterly reports .
Investment Implications
- Alignment and selling pressure: Bieberly’s disclosed equity exposure consists of a legacy 30,000 stock option grant with no available strike or vesting dates, limiting visibility into near-term selling pressure catalysts; recent proxy disclosures indicate an executive pay mix dominated by base salary and cash-based performance bonuses with no new stock grants in the past three years .
- Retention risk: CAO cash compensation is disclosed at $175k at appointment, with no disclosed severance, change-of-control, or retention bonuses, reducing certainty on retention economics compared to named executive officers .
- Governance and trading signals: As principal accounting officer and a periodic report signatory, Bieberly is central to disclosure quality; the company’s prohibition on hedging and short selling supports alignment by limiting downside protection strategies that could weaken equity-linked incentives .
- Data gaps: Absence of CAO-specific bonus outcomes, equity vesting schedules, option strike prices, severance, and change-of-control terms in available filings constrains pay-for-performance and overhang analysis; monitor future proxies and any Item 5.02 8-Ks for contract amendments or equity awards .
