Subject: File No. 4-725
From: Susan Broskie
Affiliation: Retired

October 19, 2018


I have submitted the below to my local Florida news paper. I hope you will consider the concerns of retirees in your upcoming SEC Roundtable.

Why are Special Interest Groups Targeting My Retirement Account?

Like many others, I recently retired to the Great State of Florida. My parents retired here and when my husband I came to Bonita Springs to visit with friends, we fell in love bought a home soon thereafter. We have spent our entire lives working for our four children scrimping and saving to fund our 401Ks. With our conservative portfolio some fiscal restraint, I am confident that we will have enough money to live out the rest of our lives and leave something behind for our grandchildren. However, I recently received a document from my mutual fund company and was stunned when they disclosed that they would vote proxies in accordance with Environmental, Social Governance policies or ESG. This is a direct threat to our retirement security.

I was shocked to find that one of my mutual fund companies, where my husband and I have nearly 40% of our retirement funds invested, vote proxies in accordance with what are called proxy advisory firms. These firms, who are completely unregulated, instruct our mutual fund companies how to vote on proxy ballots for public companies. One of these firms is headquartered in San Francisco while owned by a foreign entity and the other has been fined hundreds of thousands of dollars by the government for their role in a bribery scandal. How is this legal?

2016 research by The Center for Retirement Studies at Boston College has shown that funds that follow this ESG investing strategy earn significantly less that funds that dont. So why is my mutual fund company doing this despite the fact that I have no desire for them to do so?

Larry Fink, CEO of Wall Streets BlackRock, earlier this year gave his full-throated support for this feel good strategy which mandates that companies behave in a way that he sees fit. Of course, he is going to the use our money to engineer the world to his liking. Larry Fink is just a few years older than I, so I sympathize with the desire to leave a legacy behind. I wish he would do it with his own billions and not shave a few hundred thousand off of my retirement account. If Larry Fink wants to buy his way into the next world, he should do so with his money, not mine.

Thankfully, for once, lawmakers and the administration seem to be aware of this threat to retirees. In a major development, the United States Department of Labor recently released a field assistance bulletin which clearly states that fiduciaries may not sacrifice returns or assume greater risks to promote collateral environmental, social, or corporate governance (ESG) policy goals. Additionally, there is a bill, H.R. 4015, The Corporate Governance Reform Act which passed the United States House of Representatives with bi-partisan support that aims to protect retirees from foreign owned, radical proxy advisory firms legacy shopping Wall Street billionaires. This was supported by a majority of Floridas House delegation and is now before the Senate.

I hope Marco Rubio Bill Nelson the SEC work hard to get this bill passed as failure to do so will be catastrophic for all Floridians.