October 24, 2018
Mr. Brent J. Fields Secretary
A Coalition of Growth Companies
U.S. Securities and Exchange Commission
100 F Street, NE Washington, DC 20549-1090
Re: File Number 4-725 SEC Staff Roundtable on the Proxy Process
My wife and I have been preparing for retirement over the last 15 years and have invested in two large cap mutual funds. When I reviewed my annual statements and the investment criteria used, I realized that proxy advisory firms have disproportionate influence over how our shares are voted.
We are most concerned about consistent and safe returns and want to make sure these funds are acting in our best interest. When I tried to find out how and why proxy advisory firms make their recommendations, there is little information available as to why they have some of the views that they do.
I encourage the SEC to continue its efforts to provide full and open disclosure of the process used by these firms, along with any potential conflicts of interest stemming from revenue sources, ownership or political affiliations.
When two firms have such disproportionate control over so many proxy votes, an open and transparent system is critical.
I wholeheartedly support the SECs efforts toward greater disclosure and transparency.
Paul Klimas
[redacted]