Subject: File Number S7-22-19
From: John Valls

Jan. 29, 2020

January 29, 2020 

Vanessa Countryman
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
File Number S7-22-19
Dear Ms. Countryman:
As an independent investor in energy here in Texas, I am shocked and appalled with the way proxy advisory firms have been able to self-appoint themselves. These firms have excessive power and often operate hidden from view from the general public, as well as, disturbingly, many of the investors they are supposed to represent.
In essence, the two leading firms, Glass Lewis and Institutional Shareholder Services, have a duopoly on the market. They twist conventional corporate governance behind the scenes by implementing pet project shareholder proposals, specialty reports, and robo-voting practices. American companies that generally operate in good faith and within the law are being subjected to their capricious political views at the expense of shareholders. Eventually, this will derail international trade and be ruinous for our economy by decimating some of our best companies.
Texas is the number one energy state in the country, not just for oil and gas, but also for alternative resources like wind. To my knowledge, energy companies continually improved their practices, are accountable to the public, and pay local, state, and federal taxes. When they make a mistake, they pay dearly for it thanks to the careful scrutiny of regulators and the ever-watchful eye of shareholders. But they are actually leading the way in the transition to an affordable, reliable clean energy future. They should not be penalized by third parties who are not scientists and are not involved in the industry.
I strongly support closer regulations and oversight to help end the abuse the proxy firms have demonstrated. Politics should not be part of investing.
With gratitude,

John Valls