March 15, 2013
Elizabeth M. Murphy, Secretary
U.S. Securities and Exchange Commission
100 F Street, NW
Washington, D.C. 20549
RE: New York Stock Exchange Proposed Rule - Proxy Distribution Fees File No. SR-NYSE-2013-07
Dear Ms. Murphy,
I am concerned that incentives provided to brokers for developing Enhanced Broker's Internet Platforms (EBIPs) through the proposed regulations do not extend to other more open platforms, such as ProxyDemocracy.org, Sharegate.com or other websites. EBIPs offer no real benefit to retail shareholders. However, one can easily imagine brokers enhancing such systems by creating default voting mechanisms that essentially replicate "broker voting."
Please include investment advisor and beneficial owners in developing substantive amendments to address my concerns.
Harrington Investments, Inc.
1001 2nd Street Suite 325
Napa, CA 94559