Jan. 31, 2020
Secretary Vanessa Countryman SEC 100 F Street, NE Washington DC 20549 January 31, 2020 File Number S7-22-19 Dear Ms. Countryman: I am a small-business owner, so I know what risk looks like. I invested much of my life savings to launch business. In the early years, I worked 60-hour weeks or even longer, made personal sacrifices, and struggled to balance a budget with labor, overhead, inventory, and taxes and fees to consider. Fortunately, it paid off for me and I am financially secure. But many people made different bets—teachers, police, firefighters, and other public servants. They took modest pay and devoted their lives to ensure we have the services we need for our families. And they were told they had their pensions. Our state’s pension fund has given wide discretion to proxy firms that have betrayed their trust in order to promote their own personal political or social goals. For this reason, the Securities and Exchange Commission should be fully empowered to provide greater oversight into proxy firms. Alleged environmental, social, and governance (ESG) factors are supposedly at the heart of their management decision-making. I strongly suspect there are other factors we don’t even know about, possibly even some self-dealing. I’m interested in the question: where do the individuals involved in proxy firms invest their own retirements? I would guess there are more than a few hypocrites among them that have invested their own savings in more profitable, reliable assets at the same time as they sink our public servants’ hard-earned money into funds that pay meager or even abysmal returns. Consider that ESG funds often deliver half of the returns compared with the stock market. Can this even be called advising? It seems to me proxy firms are behaving more like proxy thieves. There is no doubt in my mind that they have significant conflicts of interest and have gambled with a state pension fund’s pocketbook. I don’t have a pension account myself, but I have numerous friends, family, and neighbors who do. They read the headlines every day and worry for their futures, and for good reason. The people they trusted to take care of them while they took care of our communities are guilty of the most unimaginable neglect. And for those who are sympathetic to the ESG cause, I say, no problem—you can have another retirement account. Bear in mind that it is only a matter of time before other proxy firms with opposite views take root and manipulate retirees. This has to stop. I commend the Commission for contemplating intervention into this flawed marketplace. Harold R. Krise Georgetown, TX