Jul. 29, 2025
Please retain the ability of Closed-end fund shareholders the to elect directors on an annual basis. It is the only way to ensure that their actions align with shareholder interests and allow us to hold them accountable. The concerns expressed by the Staff over the predecessor proposal to the Repackaged NYSE and CBOE Proposals apply just the same to the Repackaged NYSE and CBOE Proposals. No credible argument can be made that stripping shareholders of their right to vote at annual meetings furthers their protection and those of the public interest under Section 6(b)(5) of the Exchange Act. The Repackaged NYSE and CBOE Proposals are therefore facially and fatally deficient and cannot be approved. We are confident any relevant court would agree, should the matter come before it.