Aug. 2, 2023
Dear SEC Commissioners, I am writing to express my strong reservations and concerns regarding the proposed changes outlined in SEC Proposal S7-20-22. As an individual investor who values the principles of shareholder rights, corporate accountability, and equitable engagement, I believe that this proposal could have significant negative implications for the investment landscape and the ability of shareholders, particularly individual investors like myself, to actively participate in corporate governance. The proposed increase in ownership thresholds required for submitting proposals at company annual meetings is particularly troubling. This change could effectively silence the voices of smaller shareholders, many of whom lack the resources to accumulate the higher ownership percentages demanded. By implementing such a requirement, the proposal risks marginalizing individual investors and diminishing their ability to engage meaningfully with the companies they have invested in. Furthermore, the proposal's insistence on evidence of prior engagement with the company before submitting proposals places undue burdens on individual investors. Unlike institutional investors, we might not have the same access to management or resources to engage directly. This requirement disregards the fact that individual investors often rely on alternate means of communication to voice their concerns and suggestions. The limitations on re-submitting proposals that have not gained majority support also raise concerns. It's essential to recognize that important issues might require multiple attempts to gain traction among shareholders. These limitations hinder the accountability mechanism that shareholders rely on to ensure companies address persistent concerns over time. At its core, the proposal seems to shift the balance of power towards larger institutional investors and potentially undermines the democratic principles of shareholder engagement and influence. This risks creating an uneven playing field, where the perspectives and interests of individual investors like myself are overshadowed. In conclusion, I strongly urge the SEC to reconsider the implications of Proposal S7-20-22 on individual investors and the principles of fairness, inclusivity, and shareholder democracy. While I understand the need for effective governance, I believe there are more balanced approaches that can maintain the integrity of the investment landscape without disenfranchising individual shareholders. I kindly request that the SEC takes into account the concerns of investors like me and strives to foster an environment where all shareholders, regardless of their holdings, can continue to participate actively and make meaningful contributions to corporate governance. Thank you for considering my perspective on this important matter.