December 19, 2018
To whom it may concern,
With regards to the upcoming SEC roundtable on the proxy process (File Number 4-725), and the issue of whether the SEC's proxy rules should be "refined," I want to raise one issue that should be kept in mind when considering ways to reform the process.
There has been a recent trend among investment professionals, and especially among some large public pension funds, towards what has been termed socially responsible investing, also known as environmental, social and governance (ESG) investing. The term is somewhat amorphous, but it is essentially factoring a specific social or nonfinancial agenda into your investment decisions. Unfortunately, too often this involves social and political goals taking precedence over the needs of individual investors. Whether it be in the form of lower returns, or the pursuit of political agendas that do not comport with the views held by individual investors.
It is important that any proxy process be transparent and serve the interests of all shareholders. I hope the Commission considers the influence that politically and socially motivated shareholders and public pension funds may have under the current system (as well as the outsized role of proxy advisory firms) when looking at potential ways to reform the proxy process.