Subject: File No. S7-23-19/S7-22-19
From: Rev. John R. Long
Affiliation: Interfaith Peace Network of Western New York

Jan. 30, 2020

TO:  SEC re Proposed Changes to Rule14a-8
FROM: Rev. John R. Long, Convenor, [redacted]
DATE:  January 30, 2020
The Interfaith Peace Network of Western New York (IPN) was formed in 2003 in the run-up to the Iraq war.  IPN calls for breaking cycles of violence, focusing on root causes of conflict, seeking to re-humanize our relationships with all peoples, and upholding human dignity.  We have collaborated with several organizations in nonviolent quests for increased social justice, human rights, and sustainable economics, at local and national levels, including the Interfaith Center for Corporate Responsibility (ICCR).
We are opposed to the proposed changes to Rule 14a-8 that would substantially raise filing and submission thresholds and curb the ability of proxy advisors to offer independent advice to shareholders.  Arguing that these proposed changes will modernize operations in an era of increasing economic inequality and conflict promises only to increase tensions and an ability of all relevant parties to achieve collegial discussion and cooperative endeavors. We encourage you to reassess not only the proposed changes but a process that seeks to silence shareholders, thereby diminishing information that could be helpful to all corporate organizations.
Thank you for considering these matters.