Jan. 29, 2020
Vanessa Countryman Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: File Number S7-22-19 Dear Secretary Countryman: I would like to thank the Securities and Exchange Commission (SEC) for proposing new amendments to the rules overseeing proxy advisory firms. This is an issue that I have only recently learned the full extent of, and it directly impacts me and my retirement future. Serving my community and saving lives by being a professional firefighter has always been my dream—not only for the chance to help others, but for the opportunity to secure a comfortable life for myself with a pension to support me and my family upon my retirement. That is why the actions and business practices of proxy advisory firms have me deeply concerned about the future of the Mt. Pleasant Township Public Employee Pension system One might assume that, because these proxy advisory firms are contracted by pension and investment funds to provide recommendations and advise fund managers on proxy proposals, these companies would be providing financial advice that most benefit pensioners by securing the greatest return on investment. However, the fact is that the process is being used by activists with no fiduciary duty to pensioners who are persuaded by their own Ideological principles on a range of political and policy issues. Given that data shows such activist investing results in over 40 percent less than standard index funds, it is unconscionable to think that proxy advisors would be allowed to do this—especially given that they aren’t even required to disclose any conflicts of interest that might influence the advice they provide. This lack of accountability is precisely why the SEC must work to strengthen the rules regarding the many worrisome business practices in which these firms engage. As just one example, which the SEC already singled out in its proposed new rule changes, the practice of automatic voting—also known as robo-voting—is particularly harmful for pensioners. Pension fund managers are essentially disregarding their fiduciary duty to their pensioners by automatically voting in lockstep without review of the recommendations provided by proxy advisors. Such practice is in violation of the trust we as pensioners have in our fund's management. This unfair practice allows proxy advisory firms to push their own agendas while simultaneously jeopardizing the strength of our pensions and silencing our voices in the process. The SEC must ensure greater accountability and oversight by prohibiting automatic voting for good. Please keep these concerns in mind as you move forward in this process. It is time for proxy advisors to be held accountable for the financial recommendations they provide and the impact these recommendations have on the financial stability of millions of Americans’ pensions and investment funds. Sincerely, Kevin T. Wolford