Nancy Morris, U.S. Securities and Exchange Commission
September 29, 2007
Dear Nancy Morris, U.S. Securities and Exchange Commission,
The SEC is supposed to be the Investor's Advocate. Its role is to ensure transparency of actions by corporations and to ensure that small shareholders have a voice. But the two proposed options for shareholder proposals and director elections undermine investor rights. One would take away shareholders rights to file proxy access proposals. The second would set the bar for proposals too high, effectively blocking long term shareholders from the proxy ballot.
The costs of not allowing shareholders to act as owners are great. Enron and WorldCom hurt the economy, hurt workers and hurt retirement funds. Shareholders' ability to nominate directors would take power away CEO-dominated boards and give it back to a company's owners--its shareholders.
As an investor, I expect the SEC to protect my rights, not roll them back. I urge you to reject both proposed rules for shareholder resolutions and the election of directors.
Delegate Eleanor Norton