May. 12, 2021
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Please revise SEC regulations, if needed, to allow retail shareholders to vote using open client-directed voting. I favor the system outlined by James McRitchie in his post on the Harvard Law School Forum on Corporate Governance, An Open Proposal for Client Directed Voting (https://corpgov.law.harvard.edu/2010/07/14/an-open-proposal-for-client-directed-voting/). One key issue in any open CDV system is to let shareowners control where their electronic ballots are delivered. Just as there is no question shareowners can control where hardcopy ballots are delivered, there should be no question they can direct where their electronic ballots are delivered. This simple requirement would ensure third-party content providers an opportunity to compete and improve the quality of voting advice. Additional elements for a more effective CDV system include: A wide range of voting opinion sources that will eventually cover all issues; Open access for any new opinion sources to publish their opinions; Open access for shareowners to choose any opinion source for our standing instructions on voting; Sufficient funding for professional voting opinion sources that compete for funding allocated by retail shareowner vote (or by beneficial owners of funds that may choose to “pass-through” their votes). Under an Open Proposal, feeds will offer the ability for retail shareowners to essentially build a “voting policy,” just as institutional voters are now able to do. That model will increase participation and voting quality. We should not ask shareowners to affirm every single pre-filled ballot. That could be a deal-breaker for people with stock in many different companies who would rather spend time on other activities. James McRitchie Shareholder Advocate Corporate Governance http://www.corpgov.net