Jan. 23, 2020
Dear SEC, With regard to the proposed rule 14a-8, I am a member and ruling Elder in the Presbyterian Church (USA). I do faith and social justice work. This proposed rule will make it incredibly more difficult for smaller faith-based investors to bring issues core to our values such as mitigating climate change and human trafficking prevention, before corporate management. This seems to be an attempt to insulate companies from accountability to their shareholders. There are already robust rules in place guiding the shareholder proposal process that work well and keep frivolous proposals at bay. This proposed rule will only keep faith- and values-based shareholders, like the Presbyterian Church (USA) and other faith groups, from bringing salient issues to the attention of corporate management. Sincerely, Dr. Michael J. Adee Santa Fe, New Mexico