Subject: 4-725: Proxy Voting & Mechanics
From: William P. Flannery

Jan. 07, 2019

Ladies and Gentlemen: 

As an active investor of individual stocks I would like to submit two
comments for your consideration.

1. There needs to be a better effort to assure that all proxy votes are
counted. Barron's has reported that this is not always the case. After
spending significant hours of studying corporate Annual Reports, Proxy
Notices and other documents and submitting my votes, it is disappointing to
learn that our system for counting votes is flawed. Let's use modern
technology to get this fixed.

2. The determination of the outcome of voting should be based on the
positive and negative votes cast only. While it is understandable that some
institutions or individuals may choose to not cast votes, those abstentions
should not be considered either way. The final outcome should depend on the
counts of positive and negative votes by themselves without any assumptions
that the abstentions were meant to be in favor or against the proposals.

Thank you for your time and consideration.

Regards, Bill
William P. Flannery