Subject: File Number S7-23-19
From: Doug Walter

Jan. 30, 2020


Vanessa Countryman,
American investors and the public want more accountability from corporate CEOs, not less. I don't support increasing thresholds for filing shareholder resolutions because I believe that a say in governance is part of the value that corporations should return to their shareholders.
The federal agency tasked with protecting American investors should be encouraging a robust system of reporting, checks and balances between the owners of corporate wealth and companies’ management. Instead, I feel this will shut down the main path for providing shareholder input. These new rules would make it harder for investors to raise emerging issues with managers, meaning that it would halt progress toward addressing critical issues impacting companies and our communities over the long term. Better communication among stakeholders will result in better governance, and shareholder resolutions are an important pathway.
The SEC should be facilitating shareholder democracy, by retaining the rights of smaller shareholders to forward resolutions and have them be heard by refiling (if not initially adopted). This new set of rules should not be advanced. 
Thank you for your consideration.
Doug Walter