September 12, 2007
Dear U.S. Securities and Exchange Commission:
I am deeply disappointed that the Securities and Exchange Commission (SEC) is considering weakening my right and all Americans' right to present resolutions for votes by the millions of investors who own stock in companies. I am referring to the recent filing file number S7-16-07) by the SEC.
I urge the SEC and, if necessary, Congress to stop any initiatives that would limit the rights of shareholders to sponsor proxy resolutions or prevent investors like myself and my organization from nominating members of corporate boards. I believe that it would be better for the SEC to take no action on their shareholder resolution initiatives than it would be for the Commission to destroy the rights of shareholders.
I am worried that the SEC is on the wrong track. In my view, we need more shareholder involvement in American corporations -- not less. I strongly support the rights of shareholders to use the resolution process to encourage responsible action by often troubled companies that engage in runaway CEO compensation, poor corporate governance, a history of polluting/inaction on climate change, racial/gender discrimination and other problem behaviors.
I have seen firsthand how shareholder action can make companies better corporate citizens -- and more profitable. By ameliorating these problems, shareholders like me are able to make money in the long run. Our efforts have saved our companies from lawsuits, clean-ups, damaged company reputations and other outcomes that drive stock prices down.
I also believe that the real owners of America's companies should be able to help nominate corporate board members. This is a process that could use more openness and accountability. Investors have a duty to take their ownership role seriously. At the same time, the companies have a responsibility to investors: They should be expected to listen to their shareowners -- rather than working to limit the rights of shareholders to raise important issues, including the selection of corporate directors.
The SEC should focus on putting the interests of investors first. I urge Congress to monitor this situation and get involved to ensure that, above all other things, the SEC is the servant of the American public and its best interests. Do not allow the voice of investors to be silenced!
Thank you for your attention to my comments.
Sincerely,
Denise Moorehead