From: Brother James Gaffney, FSC
TO: Chairman Christopher Cox, Securities and Exchange Commission
FROM: Brother James Gaffney, FSC, President, Lewis University
RE: Proposed New Rules on Shareholder Resolutions
Dear Chairman Cox:
On behalf of the educational community of Lewis University, I urge you to reconsider the Securities and Exchange Commission’s proposed new rules that will weaken or eliminate shareholders’ rights to file shareholder resolutions. As you know, shareholder proposals have provided large and small shareholders with a voice in the governance of corporations for more than 30 years. Abolishing or limiting the right to shareholders’ proposals would eliminate a vital tool of management accountability to shareholders.
Lewis University has a beneficial investment relationship with Christian Brothers Investment Services, Inc. (CBIS), a faith-based institutional investor. Through active dialogues and shareholders’ proposals, CBIS representatives have been able to act on behalf of thousands of participants in their index funds, serving as an advocate with various companies and competitors on behalf of economic justice, equality and environmental stewardship.
Accordingly, I wish to voice my opposition to any attempt to weaken or cripple shareholders’ rights to file non-binding advisory resolutions under Rule 14a-8. Instead of interfering with this shareholders’ right, I respectfully ask that the SEC consider how better to protect this right. Thank you for taking my views under consideration.