December 17, 2019
Dear SEC officials, It’s my opinion that Institutional Shareholder Services (ISS), Glass Lewis, and other proxy voting advice firms are able to act as referees between shareholder concerns and public company management proposals. This proposal effectively taxes these proxy voting advice firms’ ability to say negative things about management and different management proposals. Economic theory and data informs us that company management is a classic example of a principle-agent problem, meaning that we need fair referees to informs investors about the quality of management and management proposals. These news proposals severely impede the ability of proxy voting advice firms to truthfully and honestly evaluate and communicate the quality of management decisions. This new rule, if instituted, will exacerbate management principal-agent problems thus harming the efficiency of capital allocation and lowering returns at the expense of investors. As an investor, I’m disappointed to see this newly proposed rule. In summary, I strongly oppose this new rule. Sincerely, Tina Rusch -- Tina Rusch History is a guide to navigation in perilous times. History is who we are and why we are the way we are. --David McCullough