October 5, 2018
October 5, 2018
Mr. Brent J. Fields Secretary
A Coalition of Growth Companies
U.S. Securities and Exchange Commission
100 F Street, NE Washington, DC 20549-1090
Re: File Number 4-725 SEC Staff Roundtable on the Proxy Process
Dear Mr. Fields:
On behalf of more than seven million senior citizen activists, the 60 Plus Association applauds you for the formation of the Staff Roundtable on the Proxy Process. Senior citizens are often dependent on others to guide them on what is in the best interest of their hard-earned assets that they depend on for their retirement. It is the expectation that the opinions and advice received from financial institutions is unbiased and stems from a place of full transparency.
Therefore, the proxy advisory issue is near and dear to 60 Plus and its members. It is critical that participants familiarize themselves with the numerous public comments filed so that the formation of the Staff Roundtable recommendations can be more than just lip service and really look at the issue in a meaningful way.
We have been hearing from our members about this is issue and have urged them to write to you directly so that you hear firsthand the importance of the proxy process and what it means to the senior citizens who helped shape America. Not surprisingly, one of their biggest concerns facing our membership is the assurance that an individuals money is being invested with their own financial interests in mind. Sadly, many believe they area not always being honestly and fairly represented.
The lack of transparency combined with possible biases and conflicts of interests associated with proxy advisory firms is a direct threat to the hard-earned money millions of senior citizens have saved and invested. What we are asking for is an open and fair process. For example, some of our seniors are under the false impression that fund managers are obligated to invest their money and vote on proposals that will maximize their returns for retirement. However, once an individual investor has made the decision to invest in a mutual fund, they forfeit their vote on individual stocks and rely on the entity managing their investment to represent their best interest.
Fund managers and institutional investors have a fiduciary responsibility to look out for shareholders/investors interests, and often times those same fund managers use advisory services when contemplating various shareholder proposals. If a certain bias or potential bias exists, let alone a conflict of interest exists with a particular advisory firm, it is critical that there is disclosure of such a situation.
Proxy advisors continue to operate with little to no transparency, publishing general guidelines without providing any material detail on the internal methodologies used to implement their recommendations. Put simply, proxy advisors play a pivotal role in shareholders oversight of companies.
Our ask is simple and straightforward:
Transparency in the proxy process.
A disclosure system among proxy advisory firms that notes perceived or real conflicts of interest and biases based on clientele .
We are heartened to see the SEC working on this issue and sincerely appreciate your willingness to look at this process with the best interest of seniors and all shareholders in mind. Our membership is committed to working with the leadership inside of the SEC and Congress towards the implementation of common-sense procedures, rules and legislation designed to increase transparency and fairness in the proxy process.
Thank you for your time and consideration.
James L. Martin, Founder/Chairman
Saulius Saul Anuzis, President
60 Plus Association