Subject: Rule Changes
From: Van Brenner

November 21, 2019


Hi SEC, 


I have a few comments on the proposed Shareholder Proposal Changes: 
The proposed ownership proposal seems a bit too steep. I think $5000, $10,000 and $15,000 for one, two and three years respectively would be a reasonable compromise. The resubmission proposals seem reasonable The proxy advisor disclosures are onerous and dangerous. They should be scrapped. 
Respectfully Submitted, 


Mark Brenner 
[redacted]