February 3, 2020
I strongly OPPOSE the changes to the shareholder resolution process proposed by the Commission in this rulemaking proceeding.
The SEC's current shareholder proposal process has benefited both corporations and shareholders. The current rules allow corporate managers to have an "early warning system" about issues important to shareholders and a mechanism for corporations to respond to emerging issues. Additionally, the current rules allow shareholders to responsibly push for incremental changes without the costs and burdens of additional regulations.
I fully support the comments filed in this proceeding on January 31, 2020, by the Center for Political Accountability. As the Center wrote, the proposed rule changes would disproportionately hurt small investors and harm their ability to wage multi-year campaigns for policy changes. I strongly urge the Commission to carefully look at the issue of settlement agreements, which are a critically important element here, as laid out by the Center.
Thank you,
Michael Sozan