Subject: File No. 4-725
From: Russell Heller
Affiliation: Student, Yale University

November 14, 2018

I am a student who is a part of a group that co-filed a shareholder resolution with a Fortune 50 company. I believe the $2,000 threshold for filing shareholder proposals enables smaller shareholders, even individuals, to engage with the companies they own and take an active role in the mutual pursuit of the shared goal of long term shareholder value creation. Without the $2,000 threshold, I would not have been able to be a part of this resolution process, would not know anything about shareholder engagement, would not know to vote my personal proxies, etc. The educational opportunity offered by the proxy process remains invaluable.

I believe that individual shareholders will vote their shares more often if given more information, but I think the best course of action to increase non-institutional turnout would be to enable individuals to designate institutions to vote their proxies. For example, if I wanted to allow BlackRock or As You Sow to vote my shares on my behalf, I would feel comfortable that either would vote in my economic and moral interest. Convincing people to pick someone to do the research and make decisions for them is probably easier than inspiring everyone to actually do the work themselves. Enabling trusted names to make these decisions on our behalf might be the easiest and cheapest way to increase voter turnout.

As examples - BlackRock already does the research required to vote shares on nearly every public company, so BlackRock would not undergo any additional research or investment to vote my shares according to its proxy voting guidelines. As You Sow also publishes a proxy voting guide, which I would trust that my shares could follow.