Subject: S7-22-19
From: Brian Harlin

Feb. 3, 2020

Vanessa A. Countryman, Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609
Re: File Number S7-22-19
December 18, 2019
Dear Ms. Countryman,
I own a small business and am providing for my two children, a daughter in college and a son getting ready to start college. I am happy to put in the work it takes to make a business run and happy to help my children get where they’re going. All I ask in return is some transparency in who is affecting my finances—particularly my retirement savings—and I think the new proposed rules being considered by the SEC can help with that.
 I’m concerned about the impact of unaccountable entities on my retirement funds for the reasons stated above—two kids I’ll be putting through college, and a small business with my name on all the documents. It bothers me that the proxy advisory firms advising my retirement fund managers often do so with a hidden agenda or undisclosed conflicts of interest. Conflicts that are never in the interest of regular people, I might add. That the new SEC rules require disclosure of these conflicts of interest when proxy firms are making recommendations is an understandable step to instill the confidence that everyday investors need, ensuring that our financial managers are in fact making decisions that will maximize our investment portfolios. Not to further a niche cause.
 Maybe it’s an old fashioned concept to treat others the way you want to be treated, but I still like to think it can be done. I run my business with integrity and if it takes official rules from a federal agency to get proxy firms to do the same, then so be it.
 I appreciate your efforts in this regard.
Brian Harlin