October 25, 2019
Hon. Jay Clayton Chairman U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Dear Mr. Clayton: My name is Aaron With and I am an individual investor who engages an investment advisor to professionally manage my assets. I chose my investment advisor specifically because of their expertise in integrating environmental, social and governance issues into the management of my portfolio. This includes voting my proxies, directly engaging companies, and, if necessary, filing shareholder proposals on my behalf to address issues of material concern that could impact performance, near and far. I am contacting you today to express my concern that the SEC is considering a rulemaking that would increase the amount of stock that must be held—at least $2,000 for at least one year—in order for my advisor to file a resolution on my behalf. This includes a diversified portfolio, which means my ownership share of most companies is small, but each holding is an important component of a portfolio that allows me to achieve my financial goals of being able to pay for higher education for my children. I understand that a primary mission of the SEC is investor protection. Increasing the filing threshold will serve to decrease, rather than enhance investor protection. I urge you to consider the impact of these changes to ensure that concerns of smaller investors like me continue to be heard. Thank you for your consideration, Aaron With