Subject: File Number S7-22-19
From: Larry McKinney
Affiliation: Negem & Worthington

Jan. 31, 2020


Ms. Vanessa Countryman, Secretary 
Securities and Exchange Commission 
100 F Street, NE 
Washington, D.C. 20549
File Number S7-22-19
Dear Sec. Countryman:
I am very pleased that the SEC has decided to look into the undue influence of proxy firms. I am writing to file my comments as I strongly oppose these firms and believe they should be held accountable.
Greater oversight is needed in the proxy advising marketplace as it is dominated by just two firms that essentially hold a duopoly, are entirely lacking transparent practices, and do not disclose likely conflicts of interest. These firms have abused the system continually despite their fiduciary duties to pensioners.
There is a time and place for politics, and there is a time and place for business. The two should not overlap except for the most extreme cases. Targeting a tobacco company for divestment, for instance, may be morally satisfying; but the fact is, these are legal products with companies that follow the law and yield reliable profits for their shareholders, including many pensioners like teachers, civil servants, and police. 
Those profits should be the only investment consideration, not politics. Yet proxy firms consistently deliver lower results due to their so-called ESG investing.
I find it appalling and unethical that anyone who manages a fund for others would ascribe their politics onto those investments. I am in support of far greater scrutiny of these firms, and I look forward to the SEC’s decision.
Larry McKinney
Larry McKinney 
Negem & Worthington
1828 ESE Loop 323 Suite R-1A 
Tyler, Texas 75701
Telephone:  [redacted]
Fax:              [redacted]