Subject: Rule Number 57-22-19
From: Jon Lance Zellers

December 10, 2019



Thank you, Chairman Clayton, for seeking appropriate regulation change to support meaningful financial investment policies. 


Much of "working America" depends on retirement augmentation through pooled investments. I am one of those citizens. We do not have the financial and economic knowledge to manage our accounts wisely and profitably. We need help.  


Nevertheless, we also care about the kinds of investments we have. Do they reflect companies that share our philosophies of life, human endeavors, environment, social, ethnic, and other areas? 


Investments are not just about the money. They also represent support of a personal, "owner" philosophy. 


A fund management technique has become popular. It is third-party management. While they may be efficient and profitable, they may not reflect the desires of many investors who "own a piece of the rock. 


A long time ago, in Washington, DC, I was the sole trustee of a charitable remainder trust. I was a member of the organization's board of directors. I had a direct reporting chain to the board and shared fully in the organization's investment desires and directives. I cared about the organization and where it wanted to go with it's multi-million-dollar investments. My management mirrored its direction. 


As I close out my 70th decade, I ask that you re-establish the policies, processes, and procedures for those who are contracted to manage our investments so as to strengthen the ties to what the investors want and not deviate to outside management's self-interests. 


Thank you for being a trusted steward. I wish you success in this little-appreciated corner of the SEC. 


Happy Holidays, Sir! 


Sincerely, 


Jon Lance Zellers 
Major, US Marine Corps, Retired