July 21, 2009
I am not in favor of the proposed rule changes. Current rules and regulations provide for ample shareholder protection and disclosure. In addition, a 3% or less access to the proxy statement is a low threshold and would create a nuisance to the detriment of the other 97% shareholders and add distractions and costs to the operations of a company.
Once again the SEC favors the investment banking community's sole objective of short swing gains at the expense of middle America. The only winners in your proposal are the investment bankers and attorneys at the expense of good paying jobs
Since the mid 1970s, the primary profit motive in the United States has been a shift from the production of goods and services to paper transactions. Your proposal will only help to facilitate this transition, which will mean a loss of good paying jobs to the benefit of a few.
America will continue to fall out of favor as the Country of choice to attract capital. We are witnessing in the current recession the effects of the cost of regulation as Corporate America finds it difficult to compete in the world market.
In conclusion, Directors are already held to a high fiduciary standard and most take this role seriously. The proposed rule changes will affect the dynamics in the board room and only cause the Directors to slant their interests to appease Wall Street. Middle America loses once again.