Subject: Letter re: S7-22-19
From: Martha Jones

Feb. 3, 2020

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

Re: File Number S7-22-19 

Secretary Countryman: 

I  was pleased to learn that your agency is performing its public function by recommending guidelines to make proxy advisory firms more accountable and transparent. I hope the new rules will go in to effect as soon as possible. 

In my career, I have provided marketing and communications counsel to a range of clients, including a private equity firm and an investment bank. This industry is one of the most complicated and complex fields. What all these arrangements have in common is the need for complete information, consistent with the fiduciary responsibility to investors. 

In my view, there are two issues at stake with the new SEC rule on proxy firms. One is transparency. If fund managers or financial planners are being steered to investments to make a political statement, then workers and retirees have a right to know this information regardless of political affiliation. People should be free to invest based on their own inclinations and beliefs but, more importantly, they need to clearly understand and protected from having their funds invested in ways that contradict their beliefs. 

I'm also a senior advocate, and many seniors are facing retirement short of financial resources they need. When investment returns lag, it can hurt seniors' finite resources and exacerbate the problem the country faces. If we enable proxy firms to negatively affect investment returns without accountability, this can pose a serious hardship for seniors as well as the entire retirement system. We must make protecting seniors a priority. 

As you move forward, please ensure you enact rules that will reinforce the principles of trust and transparency in retirement investing. The SEC plays a critical role in ensuring people understand their investments. Please know receiving an inch-think proxy document is not the answer. Please instill a better way to protect the long-term economic security of all Americans. 


Martha Jones