Subject: Comment to File Number S7-11-19
From: Judy Schultz

Oct. 11, 2019


Dear SEC Rule Comments, 

As an American investor and having worked for a publicly held company for decades, I know how important transparency is for shareholders and the public. The SEC’s attempt to move disclosures to a so-called “principles-based” approach is misguided and wrong. The agency tasked with protecting investors should be promoting more comprehensive disclosure, not curtailing the existing requirements. 

Shareholders and the public have a right to be informed of how corporate managers are planning for the long term on issues like climate change, board diversity and representation, and workforce development. Shareholders also have a right to know if the company they are investing in is playing in politics or moving profits overseas to evade U.S. taxes. 

It’s time for the SEC to advance disclosure, not roll it back. 

Thank you for considering my comment. 

Judy Schultz