Jan. 13, 2020
Vanessa Countryman, Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-0609 Re: File Number S7-22-19 January 11, 2020 Dear Ms. Countryman, My concern is growing over the presence of political ideology in management of public pension funds. Politics and pensions do not go together. The news of large public pension funds like CalPERS and the NYCERS being seriously underfunded due to political manipulation of funds is depressing and frightening in equal parts. It goes to show that you can be a good teacher or public servant, a loyal union member and investor for years and years and still run the risk of having nothing to show for it. Politically-driven investment in lower performing funds seems to be the largest issue at play in the CalPERS and NYCERS shortfalls. And if it can happen to them, it can happen to any of us, anywhere. Using pension funds in a show of political solidarity is grandstanding at best, totally and completely negligent at worst. Fund performance should be the priority of all parties involved in decision making at any level. If one party cannot commit to that level of fiduciary responsibility, that party should be excused from participation. The proxy advisory firms that conduct a lot of the day to day details of public pension funds and private investments seem to be the ones driving this political posturing. The SEC is in the position to correct the bad chemistry of politics in pensions and I thank you for giving this matter due attention. I strongly encourage the SEC to implement its proposed rule that would provide greater oversight over proxy advisory firms. This new rule will ensure the proxy advisory firms adhere to a fiduciary responsibility to prioritize financial returns for investors. Thank you for your time, Dominic Clark Teacher and pension fund investor Orange County, Florida