Subject: File No. S7-22-19
From: Dexter Burney

February 2, 2020

Vanessa A. Countryman, Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609

Re: File Number S7-22-19

February 2, 2020

Dear Ms. Countryman,

I draw a pension from the Orlando Utilities Commission Pension Plan and I am concerned that outside forces could destabilize the fund with reckless behavior. Specifically, proxy advisors whose firms make recommendations for shareholder proposals. Recommendations that often fail to benefit the growth of our pension plan.

Pensions are a promised benefit for some workers and are needed to support many people and often for many years. When managed effectively, pensions have proven to be the most beneficial retirement plan. While we are working, pension contributors and our employers are contributing to our retirement years. Often there is not a lot of money left over after each paycheck for investing in other savings. And a pension fund failing should never be a possibility.

Nowadays though, pension funds across the country are being destabilized by the questionable actions of proxy advisory firms that are making recommendations that do not prioritize growth.

These firms should be required to put pension growth first and there should be measures in place so that pension investors have a course of action if proxy advisors do not heed the rules. I know the banks were the ones that were too big to fail in 2008, but I think the same could be said of American pension funds today—too many people have worked too hard and rely on these funds too much to let proxy advisory firms have such an outsized and largely unaccountable impact on them through the proxy process.

Thank you,

Dexter Burney
Orange County, FL