Aug. 12, 2023
To whom this may concern; Re: Comment on SEC proposal S7-6-22 I am not in favor of endorsing this proposal. My stance against this proposal remains unchanged, primarily because the existing regulations are designed to uphold the authority over a company's decisions by individuals who have a long-term investment interest. These investors comprehend the complete value and associated risks of a security and consider them a justifiable expense in exchange for the opportunity to contribute to a company's prosperity. They also view this participation as a means to voice their opinions regarding strategies that safeguard and advance their investments. My opposition to this proposal persists due to multiple reasons. The present system ensures that dedicated investors, genuinely interested in a company's growth and evolution, possess a balanced influence in pivotal decision-making processes. This framework also empowers companies to gauge the commitment and endorsement they receive from individual investors, thereby aligning with their values, principles, and propositions. I wish to reiterate my non-support for this proposal for the reasons previously discussed. Restricting these privileges to original security holders provides companies with deeper insights into the convictions and perspectives of investors who perceive intrinsic value in the company, extending their capacity to identify, respond to, and acknowledge those advocating for these rights. Such alignment with a company's goals and broader philosophy ensures a higher level of certainty when decisions are made, reflecting the intent of those investors who purchased securities with the aim of endorsing non-financial ideals and overarching benefits for the company beyond financial gain. Adopting a more skeptical outlook, allowing external institutions to acquire these rights—potentially through derivative instruments at a fraction of traditional investors' costs—might lead to an imbalance in representation. This could inadvertently favor those with limited historical commitment, at the expense of the long-term investors who bear the primary repercussions of resultant choices, ultimately silencing their voices in critical matters. Please be aware of my unwavering disapproval of this proposal. Sincerely, Darren A. Zebari