Subject: File No. S7-17-07
From: Jorgen I Overgaard
Affiliation: Accountant

September 17, 2007

It should, if anything, be made easier for small shareholders to nominate members for the board of corporations, NOT harder, as you propose.

It would be virtually impossible for smaller shareholders to collect 5% of the shares to propose alternative board members. And what is there to loose by putting up some alternatives, if a majority of the shareholders don't like them, they will not be voted in anyway.
But real democracy is not in high esteem these days whether in companies or the country as a whole, so why are we not surprised that you propose weakening it further?


As it already is, avoiding company proposed board members is almost impossible. The reality is that who gets on boards are most often in reallity controlled by company management, with a minor input from existing boards.
This makes it almost impossible to get rid of the board/management collusion when the combination goes bad, as happens quite often.
Jorgen Overgaard
Shareholder in many companies