Subject: Regarding File Number S7-22-19
From: James Beauchamp

Feb. 3, 2020

Vanessa Countryman, Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609
Regarding File Number S7-22-19
February 3, 2020
Dear Secretary Countryman:
I’m certain the SEC is hearing from a lot of concerned investors and pensioners about the risks to our retirement funds thanks to proxy firms with no stake in our retirement savings and the outdated rules governing the proxy process that allow them to act with impunity. 
One aspect of this ongoing discussion that may not get as much press is the use by proxy advisory firms of what are called specialty reports. The SEC has rightly addressed this issue in its proposed rule on proxy firms. In essence, these are a way for proxy firms to push the ideological agenda of specific large clients with no regard for financial returns that impact—negatively, by the way—the rest of the investors and clients in a fund. 
Specialty reports let a big firm gain a reputation for caring about the environment and other social issues—and that’s fine for those companies—but it is most definitely not fine for the retail investors and even the public pension investors who see their savings take a hit in the name of someone else’s ideology.
Ideological investing like this is proven to produce returns that are nearly half as lucrative as investments made with an eye to maximizing returns. Which is how all investments with other peoples’ money should be made. Ideology is for political campaigns, not investing other people’s money.
Placing all proxy firms, and especially Glass Lewis and ISS, which dominate the majority of the proxy market, under closer scrutiny when it comes to their motivation for recommendations makes a lot of sense to everyday investors. 
If the big financial firms want to cater to their big financial clients, they can find other ways to do it. It better not happen on the backs of normal people saving for our own retirements. 
Thank you for all that you are doing on this issue,
James Beauchamp
Midland, TX