Jan. 14, 2020
Ms. Vanessa Countryman, Secretary Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: File Number S7-22-19 Dear Sec. Countryman: In my work at an accounting firm in Brevard County, Florida I have developed a strong sense of smart retirement planning and changes that affect how much people’s money is growing. I have also noticed that many retirement savings plans are more and more influenced every day by organized efforts to direct investments in what can be characterized as politically correct. I believe it is time for the Securities and Exchange Commission to make clarification here and make sure companies involved in submitting proposals for shareholder votes do so with investors interests at heart. The proposed rules under consideration make sense. I am concerned most average savers and investors are not aware of how much today’s methods of political activism can affect their personal finances. They might not realize many resolutions put forward at shareholder meetings, or open to proxy voting, are being pushed by outside interests that specialize in managing how these resolutions are presented and voted on by shareholders. Certainly, these firms are meant to provide a valuable service to fund managers and publicly traded companies but the principles have strayed. The SEC must ensure people can trust that these firms are not limiting investment returns in the name of policy advocacy. Private pensions have become a rarity but millions of teachers, clerical professionals, firefighters, police officers and others still rely on a pension for retirement. These days, many people have a 401(k) or an IRA. Regardless, they all want their money to grow as much as possible as they reach their retirement years. The views of a select few on issues such as the environment, gun ownership, diversity in boardrooms, and other issues should not operate counter to the goal of solid returns on investment. In fact, financial professionals have a legal duty to people who work, chiefly to get good returns for them and help them achieve a secure retirement. I believe the proposed rules for reporting requirements will not be a burden on proxy advisory firms but these rules will be in the best of interest of shareholders large and small. I am pleased the SEC is taking these actions. Sincerely, Beth McMillen