Feb. 2, 2020
Vanessa A. Countryman, Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-0609 Re: File Number S7-22-19 Dear Secretary Countryman, During my time as senior vice president for Premera Blue Cross I was required to make many difficult decisions for the good and long-term benefit of the company. I am certain that you are hearing from many people with many opinions on File Number S7-22-19 and I hope that ultimately you will pursue the greatest good for the greatest number of people in your final decision. To that end, I believe that increasing regulation on the proxy advisory firms that dominate the proxy market is a crucial step to take. Proxy firms are largely unregulated at the moment; this alone should be concerning to investors. Add to that the fact that two firms, Glass Lewis and Institutional Shareholder Services, dominate 97 percent of the proxy advisor market and the stakes increase. So long as these firms can make recommendations based on ideology and not financial returns; can overstep their bounds by making vote recommendations and then casting the actual votes; and have virtually no repercussions for proxy advice that decreases gains and damages nest eggs of all shapes and sizes; if all these things remain true then American investors are in for a world of hurt during our most vulnerable years. Thank you for your attention to this problem and I hope you are able to make the difficult decisions that must be made to protect investors. Thanks very much for your time, Jack McRae Edmonds, WA Sent from my iPad