Dear SEC Staff and Commissioners, I respectfully submit the following opposition to SR-CboeBZX-2025-072, which seeks to exempt newly listed closed-end funds from holding annual shareholder meetings as required under Exchange Rule 14.10(f) 1. Undermines Shareholder Rights and Governance Oversight Annual meetings are the primary venue for shareholders to: Elect or re-elect directors, including independents, who oversee fund management. Attend to critical governance issues, such as approval of significant policies or conflicts of interest. The Exchange's proposal incorrectly claims that the Investment Company Act and 1940 Act provide sufficient governance safeguards However, these federal statutes do not guarantee annual board elections or provide a forum for shareholder-initiated questions, representations, or accountability that in-person or virtual meetings facilitate. 2. Increases Risk of Entrenchment and Reduced Transparency The Exchange argues the exemption may help new funds avoid "activist exploitation of retail investor disengagement" This rationale is unsubstantiated and concerning: It biases against shareholder activism, which drives better governance and value discipline. Without a formal meeting requirement, fund boards may operate with diminished oversight and fewer engagement obligations. Retail investors-already bearing NAV discount burdens inherent to closed‑end structures-will be particularly disadvantaged by diminished transparency and fewer engagement opportunities. 3. Creates Unfair Governance Asymmetry Granting an exemption only to funds listed after May 20, 2025 introduces arbitrary differential treatment: Existing closed-end funds remain subject to annual meeting rules, while newcomers are exempt. This unequal treatment establishes an unfair precedent and could lead to two classes of funds: one with full shareholder accountability and one without. The proposal's "grandfathering" of older funds doesn't justify stripping new funds of the same foundational governance protections 4. Cost-Savings Do Not Justify Weakening Governance The Exchange justifies the exemption on cost-saving grounds, suggesting that meetings impose undue expense However: Many funds already opt for virtual or hybrid meetings, greatly reducing costs while preserving accountability. The marginal cost of mandatory meetings is negligible compared to the structural benefit of robust shareholder oversight. Cost shouldn't supersede long-established principles of transparency and accountability. Conclusion & Recommendation In light of these concerns, I urge the Commission to reject SR-CboeBZX-2025-072.