Subject: File No. 265-28
From: Brett J Davidson
Affiliation: Individual Investor

February 6, 2013

I fully support Jim McRitchie's proposal that will end Broadridge's regulatory abuse that occurs when they treat voter instruction forms as if they are not subject to the same regulatory framework as proxies.

The IAC should ask staff for a legal opinion discussing what legal requirements apply to VIFs and how, if at all, do they differ from those that apply to proxies. The IAC should recommended changes necessary so the same protections are afforded to retail investors as are afforded to shareowners with direct registration.

Regulatory action should be taken against Broadridge to force them to cease violating rule 14a-4 and to protect shareholders suffrage rights.

The IAC should try to level the playing field by recommending the Commission take action on the rulemaking petition to eliminate blank votes from automatically going to management submitted by James McRitchie and others at

The IAC should recommend the Commission amend Rule 14a-4 to remove the provision that confers discretionary authority on matters where choice has not been specified by the security holder or beneficial owner, should explicitly extend such prohibition of discretionary authority to companies where beneficial owners fail to provide instructions, and should make similar amendments to other rules that may provide such authority.