October 7, 2021
Firstly, the SEC does not make it simple for the public to comment on these rules. The pdf in question is 174 pages long and seemingly written to obfuscate rather than enlighten.
You claim to be open to public comment, but your actions speak otherwise.
I have one comment: Every single shareholder vote should have a public audit.
It is well known that the DTCC and whatever other SROs involved 'cook the books' on proxy votes because of rampant over voting. Manually making the REPORTED number of votes match the official number of shares outstanding is fraud plain and simple.
Not only is this common practice, but this is well known.
Why is there rampant over voting? Fails and borrows. Positions that are allowed to remain unclosed for years.
Honestly, I as an investor have zero confidence in the SEC's commitment to protecting me and my fellow investors. So, I am skeptical that an audit would solve anything because the audit could quite easily be fabricated just like the vote tallies.
We require a much more significant change.
I propose that 2 weeks before a corporations shareholder vote begins a mandatory closing of ALL open positions for that ticker must be completed. This would include fails, shorts, and the obligation warehouse.
Shareholder votes are annual. Let's have a mandatory annual re-set of each and every ticker in the market.
You want a level playing field?
Prove it.