Jan. 22, 2020
Ms. Vanessa Countryman Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 January 14, 2020 Dear Ms. Countryman: I wish to add my comments to File No. 7-22-19: Amendments to Exemptions from the Proxy Rules for Proxy Voting Advice. I applaud the Commission for its recent action and its ongoing review of the process on this issue, and I especially admire the SEC’s willingness to involve the public. I am a retired art teacher from the Lincoln Public Schools, and my retirement is managed by the municipal employee’s retirement system (MERS) through the state of Rhode Island. My family relies on that pension. I wrote a comment last year, and my views have not changed: proxy advisory firms have too much power and too little accountability. I’ve discovered a few more things subsequently and thought I’d build upon my previous comments. MERS is actually in relatively sound shape compared to the unfunded liability for the 34 locally managed pension plans in Rhode Island which are $2.4 billion underfunded. While MERS is solvent for now, recent headlines regarding other pensions cause me concern. If proxy advisors are allowed to continue their aggressive political practices with no accountability, it could spell disaster. This is particularly true because socially responsible investing has been proven to return significantly less money on investments as compared to more historically stable investment funds. The practices these firms use beyond ESG are very suspect to say the least. In particular, robo-voting allows pension fund managers to discharge their duty by automatically voting in alignment with proxy advisory firm recommendations, despite specific considerations they should be making for the position of their pensioners or investors. I am sure that is just the beginning. There are so many redundancies and conflicts of interest, combined with little to no transparency, that it is clear these firms will eventually cause significant problems. The SEC should keep up the good work because this has gone on too long. Sincerely, Louis Fusco