September 25, 2007
Chairman Christopher Cox
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090
Dear Chairman Cox:
As an accountability activist shareholder in a large number of publicly traded companies both personally and as a portfolio manager, I'm writing to request that you protect the right of investors to file shareholder resolutions and urge you to take no action on the proposed initiatives that would curtail or eliminate this essential right.
Shareholder resolutions are an invaluable tool for investors who want to make their voices heard with regard to the direction of their companies. Shareholder resolutions have helped to promote transparency and improve corporate governance and performance. They have called attention to critical issues, including global warming, nuclear power, sweatshops, executive compensation, natural resource extraction, and other major societal and environmental problems that, when not addressed, often end up costing shareholders and their companies as a result of lawsuits, damaged reputations, consumer boycotts, public protests, and low staff morale.
The many corporate scandals of recent years highlight how important it is to have more, not less, corporate transparency and accountability. Shareholder resolutions have proven effective in holding companies accountable to their owners. I ask that the commission safeguard, not undermine, their use.
Thank you for your attention to my comments.