Subject: File No. S7-23-19
From: Todd Snyder

January 30, 2020

I strongly oppose this despicable effort to block shareholder oversight. As an investor, I demand more accountability from corporate CEOs. As a publicly funded agency, the SEC must fulfill its mission to protect investors. 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 Boeings 737 MAX model aircraft killed hundreds of people, the companys shareholders filed proposals asking for more transparency about the companys lobbying, citing concerns about the companys influence over regulators. Had the new rules been in place, those shareholders efforts to hold Boeings management accountable would have been stopped in their tracks.

The SEC must facilitate shareholder democracy, not undermine it. This new set of rules should not be advanced.