February 13, 2022
Given the fact that incompetence, anti-Black discrimination and exclusionary practices based on race are currently operational in investment and finance, including at the SEC and other regulatory bodies, we decline to directly address the questions raised, having done so over the past 30 years. Additional specific input would be futile. We note, however, Mr. Cunningham (WMC) has long been concerned with the failure of bank and financial institution regulatory agencies to protect the public interest. We base this on the following and we incorporate these comments by reference:
Our 2003 comments on proposed proxy voting rules that would, under certain circumstances, require companies to include in their proxy materials security holder nominees for election as director.
https://www.sec.gov/rules/proposed/s71903/wmccir122203.pdf
See: Comments on Proposed Rule: Internet Availability of Proxy Materials Release Nos. 34-52926 IC-27182 File No. S7-10-05. Confirmed that system-wide economic and market failure was a growing possibility. (See page 2:
http://www.sec.gov/rules/proposed/s71005/wcunningham5867.pdf )
Shareholder Proposals Relating to the Election of Directors. Release No. 34-56161 File No. S7-17-07 https://www.sec.gov/comments/s7-16-07/s71607-495.pdf
Roundtable Series on Giving Investors and Analysts Better Financial Data via Internet Interactive Data and eXtensible Business Reporting Language (XBRL) Voluntary Program. File No. 4-515. https://www.sec.gov/news/press/4-515/wcunningham7465.pdf
We have requested that the U.S. Securities and Exchange Commission (SEC) develop mandatory rules for public companies to disclose high-quality, comparable, decision-useful information concerning BLM Pledge fulfillment. See: https://www.sec.gov/rules/petitions/2021/petn4-774.pdf