November 30, 2019
Hello, I am writing to oppose the proposed eligibility amendment to Rule 14a-8 as presented. I understand the concerns regarding potential abuse of company resources by shareholders with little meaningful investment. However, I believe that disenfranchising small investors is a more significant problem, and will only be exacerbated by increasing the threshold for investors to be permitted to submit 14a-8 proposals. In fact, I support making the eligibility threshold as low as possible, as a minimum investment of $2000 in a single company is still more than many people can afford (especially those of us who try to diversify our assets, as conventional wisdom and pretty much every professional recommends, while still working on a shoestring budget). I think there is some merit to the tiered time/money approach presented in your proposal, but I would still change the numbers - at three years, anyone with even a single share should be eligible, regardless of dollar value. Again, I recognize the risk of abuse as described in your proposal, and the need to balance this with shareholders' rights. I think there is a better solution, however, than disenfranchising small investors. As your proposal itself states, there have been great advances in communication technology since the last time 14a-8 eligibility requirements were adjusted. This means that, rather than restricting who can use up resources on proxies, the solution might be to change the whole "proxy" system so that it costs less of a company's resources. Modernizing the whole system in which shareholders vote on company matters, and submit their own proposals to be voted on, may save far more resources in the long run than limiting access to sufficiently wealthy investors. I urge the SEC to look into this as a better solution to the problem of waste and abuse through proxies. thank you, Josh Feldblyum Philadelphia, PA