January 28, 2020
Ms. Vanessa Countryman
Secretary SEC
100 F Street NE
Washington, DC 20549
Dear Ms. Countryman:
I am writing on behalf of The community Church of New York. We are based in New York City and are a religious investor active over the years in shareholder engagement including the filing of resolutions. We work closely with our investment manager to insure that our faith based values are properly reflected in our portfolio and our public outreach to companies.
We have been involved in the filing of resolutions as one part of our responsible investment commitment for numerous years . Thus, as you can imagine, we are deeply concerned that the new SEC rules may hinder our ability as a small shareholder to participate in future shareholder resolutions. As we have studied the proposed SEC rules we are disturbed by the bias against smaller investors who do this as part of their mission but have limited resources to do so .
We have just studied the ICCR comment letter submitted on Jan. 27, 2020 (see enclosed). We believe it made a powerful and convincing case. Certainly it thoughtfully represented the concerns of hundreds of religious investors, small and large, We urge the Commissioners and SEC staff to study it carefully.
We believe this is a time that the SEC should be protecting and opening up investor rights rather than attempting to eliminate or limit them.
Sincerely,
Jeff Loveland
Director – Finance and Operations
Community Church of New York Unitarian Universalist
40 East 35th Street
New York, NY 10016