Subject: File No. 4-670
From: Mark Latham
Affiliation: Founder,

November 28, 2013

Please consider the possibilities for improving competition, incentives and performance of proxy advisory firms, outlined in the attached three files:

1. Proxy Advisor Competition - shareowner proposal.pdf

2. Comments by Mark Latham on SEC Proxy Concept Release.pdf

3. Proxy Voting Brand Competition - Journal of Investment Management.pdf

Thank you for working on this important policy issue

(Attached File #1: 4670-1a.pdf)
(Attached File #2: 4670-1b.pdf)

Copyrighted material redacted. Author cites:
Latham, Mark. "Proxy Voting Brand Competition." Journal Of Investment Management 5.1 (2007): 79-90. Print. Available at Retrieved 2 December, 2013.