Subject: Letter RE: S7-22-19
From: Bob & Jane BURMEISTER

Feb. 1, 2020

February 1, 2020 

Vanessa Countryman 
Securities and Exchange Commission 
100 F Street, NE 
Washington, D.C. 20549 

Re: File No. S7-22-19: Amendments to Exemptions from the Proxy Rules for Proxy Voting Advice 

Dear Sec. Countryman, 

As a pastor, I make a modest salary, and certainly money is not the reason anyone follows a calling into the Church. However, it is through my savings that I am able to secure a comfortable retirement for my future. That is why I believe it is necessary for the Securities and Exchange Commission to provide more oversight of the two firms that control the proxy advisor market in the United States. 

Rather than making recommendations based on the best financial interests of investors, these firms are making recommendations based on political views. That means less return on my investment, and a more uncertain financial future when I eventually retire.  The same is true for our parishioners.  Of course, individual investors are entitle to invest based on their values.  It should not be acceptable for proxy advisors to impose their values on the investments of others, especially when these decisions have a deleterious impact on investment returns. 

I am pleased to see the SEC taking up this issue and issuing guidance clarifying the role these firms play in managing—and hopefully growing—the pensions of folks across the country. It is time for the SEC to step in and ensure that proxy advisors are being held to the same accountability standards as any other company, especially given their outsized role over determining the investments and retirements of hardworking Americans.  


Pastor Robert Burmeister