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 Dear Sec. Countryman: The behavior of proxy advisory firms is disturbing, so I appreciate efforts by the Securities and Exchange Commission to rectify this situation. Of course, normal people/retail investors are responsible for keeping an eye on their own investments, but it should not be the job of normal people to police the behavior of these firms. Particularly when we normal people have no recourse in using these firms. Glass Lewis and Institutional Shareholder Services occupy 97% of the proxy advisor market, so misbehavior on their part affects many investors and leaves these same investors with no option to do anything about it. These proxy firms often allow their political perspectives to influence their vote recommendations and damage investor returns as a result. Advising fund managers with environmental, social, and governance policies as the foremost drivers of recommendations proven to produce fund returns 43.9% lower than even a standard S&P 500 index fund. For a fund to underperform by such a large margin is ridiculous. As the body that oversees how the firms within the financial world behave, I’m sure that none of this is news to the Commission. I’m just hoping that the proposed rules will fix the status quo. Joel Mattila Clark County, Washington