Subject: SR-CboeBZX-2025-076: Webform Comments from Aaron Morris
From: Aaron Morris
Affiliation: Partner at Morris Kandinov LLP

Jul. 7, 2025

For reasons that are long established and obvious,
closed-end investment funds should not be permitted to operate without
regular annual meetings. Holding an incumbent manager accountable is
hard enough with an annual meeting, given the lengths (legal and
illegal) that advisers will go to preserve their contracts and their
hand-selected "independent" directors. Managers have the
choice to compete on merit or try to rig or close the polls. Given the
emergence of illegal control share bylaws, poison pills, impossible
quorum requirements, tilted election thresholds only applicable to
challengers, and now the second round of the proposals to do away
entirely with meetings, it is clear that the industry has no interest
in the kind of healthy competition that otherwise fuels our economic
system. Any proposal that weakens a shareholder's right to an
annual meeting should be rejected.