March 27, 2009
Elizabeth M. Murphy, Secretary
Securities and Exchange Commission
100 F Street, NE, Washington, DC 20549-1090
via e-mail on March 27, 2009
Dear Ms. Murphy:
I write in support of the rule to eliminate uninstructed broker votes in corporate director elections. I urge prompt approval of the NYSE's proposed changes to Rule 452. Legalized ballot stuffing was a bad idea, and it is past time to end it.
We also need to do a better job of informing average citizen investors of the importance of using their votes via the proxy. Let's face it, many companies go out of their collective ways to make such votes obscure and complex. We need alternatives.
One strategy, being pursued by the Investor Suffrage Movement (ISM http://isuffrage.org/ ), is to simply develop a system that will allow shareowners to assign their voting rights to someone else... someone who will take the time to figure out how to vote, based on substantial research.
Another strategy is that of ProxyDemocracy (PD http://proxydemocracy.org/ ), which develops systems that facilitate the retail investor's ability to learn from and/or copy the vote of thoughtful institutional investors that announce their votes in advance of annual meetings.
Both of the above ideas are innovative and sensible. The SEC should approve the proposed rule immediately and should then educate the public on the importance of proxy voting, encourage institutional investors to announce their proxy votes in advance of meetings, and should facilitate the development and spread of systems like ISM and PD, which help retail investors vote more intelligently.
Sincerely,
Larry S. Dohrs, Vice President
Newground Social Investment