Jan. 14, 2020
Jay Clayton, Chairman Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-0609 January 14, 2020 Re: File No. S7-22-19 Dear Mr. Clayton, It is good news that rules applying to proxy advisory firms are under consideration. I am fortunate to be part of the public employees’ retirement system for the state of Ohio. My parents also have some of their retirement money invested in this system as well. The pension system gives us some peace of mind that we will have money needed to retire comfortably after serving the people of Ohio over our working lives. Like most people, I work hard for my money and I expect the money I put in the pension plan will work hard for me too. I feel proxy advisors have overstepped their roles and this could undermine the performance of the pension plan for me, my parents, and other workers in Ohio. To state what should be obvious, proxy firms should serve investors not political activists and causes. This seems to have gotten lost as their power has grown beyond simply providing administrative backup. Comments generated to the SEC’s docket on proxy advisory firms proves the real problem that exists. These firms disclose little to nothing about who their clients are or how they propose or determine recommendations on shareholder resolutions. We need to change this and the proposed rule will nail down reporting requirements so it clear to all how proxy firms work and what their agendas are. Political activism and investing do not go hand in hand. It creates conflicts of interest and stirs controversy. Since proxy firms are at the center of these controversies, the SEC has taken the right steps to shine a light on this and prevent actions that can reduce long-term returns on investment. This will serve the interests of public sector workers and all others who want their money to grow as much as possible. Thank you for taking this matter seriously. Sincerely, Brennan Clegg bclegg25@gmail.com 614.202.9235