September 8, 2007
Dear Chairman Cox:
I believe it would be unwise to destroy the nonbinding shareholder proposal. Shareholder proposals are essential to allowing the slowly developing ethical and social issues to be quickly reflected in corporate America.
I am concerned that questions raised by the SEC may lead to the restriction or elimination of shareholders' rights to propose advisory resolutions under Rule 14a-8. As an investor, I regard shareholder resolutions as a valuable tool for shareholders to make their voices heard about the direction of our companies. I specifically oppose granting companies the ability to "opt out" of the shareholder resolution process or substituting electronic petitions or chat rooms for resolutions.
It is to the credit of the SEC and our democratic system that small investors as well as large ones can participate in this process. Many of the most critical corporate reforms of recent years have been promoted by these small individual and institutional investors. The current proxy rules have facilitated a rich and diverse dialogue on some of the most critical issues of our time, from climate change to excessive executive compensation. I urge you to keep these current rules in place.
The many corporate scandals of recent years have underlined the importance of more communication, more transparency, and more accountability - not less.
Please understand your responsibility in this situation is to foster all investors, both large and small, in improving the effects our corporations have on society.