Subject: File No. S7-24-19
From: William Michael Cunningham
Affiliation: Creative Investment Research

February 1, 2020

We stated, on February 5, 2015, in testimony to the Norwegian Ministry of Finance
( and on April 22, 2015 in testimony to the Government of the United Kingdom:

As the market value of environmental, social and governance factors continues to grow, companies and investment managers will engage in fraudulent practices related to these factors. These practices will range from simple falsification of environmental, social and
governance records to more sophisticated, but no less fraudulent methods related to environmental, social and governance ratings.

On September 22, 2015 automaker Volkswagen admitted that defeat devices used to cheat emissions testing were installed in 11 million vehicles worldwide.

Also see: Comments on Proposed Rule: Internet Availability of Proxy Materials Release Nos. 34-52926 IC-27182 File No. S7-10-05. Statistical models created by the firm using the Fully Adjusted Return Methodology confirmed that system-wide economic and market failure was a growing possibility. (See page 2:

See: Comments on the SEC Proxy Process Roundtable. File No. 4-537. May 11, 2007.

See: Shareholder Proposals Relating to the Election of Directors. Release No. 34-56161 File No. S7-17-07

We incorporate these comments by reference.