Subject: Comment to File Number S7-23-19
From: Sally Goldin
Affiliation: Goldin-Rudahl Systems

Jan. 18, 2020

 

Dear SEC Rule Comments, 

Corporate shareholders are the ultimate owners of a company, and bear responsibility for that company's actions. That is why it is essential that investors and shareholders be able to hold corporate CEOs accountable for decisions that might harm the public or the shareholders themselves. 

The new rules proposed by U.S. Securities and Exchange Commission will make it more difficult for shareholders to raise critical issues with corporate management and will greatly decrease the transparency of the corporate decision process. 

In the years before Boeing’s 737 MAX model aircraft killed hundreds of people, the company’s shareholders filed proposals asking for additional information about the company's lobbying efforts and attempts to influence regulators. These proposals now constitute critical evidence that Boeing acted unethically, perhaps criminally, in the 737 MAX case. The proposed new SEC rules would have stopped these shareholders' proposals from being submitted and severely limited the shareholders from exposing Boeing's responsibility. 

We need greater transparency in corporate governance, not less. I strongly urge the SEC to drop the proposed rule changes. 

Sincerely, 
Sally Goldin 
[redacted]