Subject: File S7-23-19
From: Timothy M. Warren, Jr.
Affiliation: First Parish in Cambridge

February 6, 2020

Ms. Vanessa Countryman
Secretary SEC
100 F St. NE
Washington, DC 20549

Dear Ms. Countryman,
I am writing on behalf of First Parish in Cambridge, a Unitarian-Universalist church based in Cambridge, Massachusetts. Our church has been active for over fifteen 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. 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 enclosed ICCR comment letter submitted on Jan. 27, 2020 (see attached). We believe it made a powerful and convincing case. 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. Small investors and those who are guided by their religious convictions should not be silenced.


Timothy M. Warren, Jr.
Chair, Investment Committee
First Parish in Cambridge
3 Church Street
Cambridge, MA 02138