Subject: File Number S7-22-19
From: Donald Kasych

Jan. 15, 2020



Jay Clayton, Chairman
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609
 
S7-22-19
 
Dear Mr. Clayton,
 
I am writing to express support for new rules concerning outside firms that handle shareholder votes at board meetings for companies and investment funds.
 
People in Northeast Ohio have experienced a lot of economic change over the years, a lot of it unpleasant. As good-paying jobs disappeared, making ends meet and saving for one’s later years has become difficult for many people. As I near retirement I consider myself lucky to have Ohio’s Public Employees Retirement System to rely on. After over 30 years working for the City of Cleveland and the Lorain County Metropark system, my wife and I fortunately will have money to live on. I know a lot of people are not that fortunate, which is the basis for my comment.
 
When I learned that systems like OH PERS are vulnerable to politically-skewed investing I was very concerned. Public pension plans are in trouble all over the country. This kind of investing often means less growth. With the less growth, PERS and others systems will not be able to provide future retirees with the benefits they are expecting, at least not without raising taxes. That is not fair for anyone and it can be avoided with better rules.
 
I don’t think it is right to gamble with the retirement savings of public employees to make a political statement. If someone wants to put all their money into green industries or companies with very progressive corporate policies that is fine. What is not fine is when the firms that are supposedly just handling the logistics of proxy voting end up making those decisions and getting less growth from the investments
 
The SEC is correct to insist these companies publicily release their clients and the work they perform for those clients. These firms have provided proxy recommendations related to companies and when their recommendation goes against management, found themselves hired by that company with the hope of producing a positive recommendation in the future.
 
I ask that the SEC produces reform that increases transparency and requires all entities involved with my money adhere to their fiduciary responsibility. Such reform would ensure greater confidence in the investment process.
 
Thanks,
 
Donald Kasych

Sent from my iPad