Jan. 15, 2020
Vanessa A. Countryman, Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-0609 Dear Secretary Countryman, I write in full support of the proposed rules changes for proxy advisory firms that the SEC is pursuing for the simple reason that I’m interested in portfolio growth for my retirement funds and other investments. As a small business owner approaching retirement, my primary concern now is the health of the retirement funds my wife (now retired) and I will rely on. We made sacrifices in our working years to be where we will be during our retirement. It would be negligent for an overseeing agency like the SEC to allow unaccountable proxy advisors to knowingly shift the direction of pension and private investment funds from a direction of growth to one of stagnation or declining value based on political, not financial reasoning. The existence of these firms in the grand scheme of finances and investment is not where I take issue. In fact, I think the use of proxies keeps financial managers from having to start at zero with research and deliberation each time there is a shareholder meeting or shareholder proposal or question of corporate governance. Being able to outsource these details keeps the minutiae of management to a minimum. Unfortunately, proxy advisory firms are not just doing research, they are using their position to push political and social causes. New rules dictating the disclosure of conflicts of interest on the part of advisory firms are on point. To have a uniform understanding of when failure to disclose information in proxy advice constitutes misleading investors means that advisors and managers are all playing by the same rules and investors can know what to expect. The last thing any retiree wants is an unpleasant financial surprise. Brett Malin Seaview, Washington