Subject: Comment to File Number S7-23-19
From: John Curley

Mar. 12, 2020

Dear SEC Rule Comments, 

As a shareholder/owner of a publicly traded company, I have the right to ask for and receive information about large expenditures on the companies lobbying efforts. 

We need information to hold corporate executives and the board of directors accountable, to we the owners. 
The SEC’s attempt to crush shareholder oversight is reprehensible. 

The federal agency tasked with protecting American investors should be encouraging a robust system of checks and balances between the owners of corporate wealth and companies’ management, not shutting 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. 

Years before Boeing’s 737 MAX model aircraft killed hundreds of people, the company’s shareholders filed proposals asking for more transparency about the company’s lobbying, citing concerns about the company’s influence over regulators. Had the new rules been in place, those shareholders’ efforts to hold Boeing’s management accountable would have been stopped in their tracks. 

The SEC should be facilitating shareholder democracy, not undermining it. This new set of rules should not be advanced. 

Thank you for considering my comment. 

John Curley 
2 Bufflehead St 
American Canyon, CA 94503