Jan. 16, 2020
January 16, 2020 Secretary Vanessa Countryman Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 Re: File No. S7-22-19: Amendments to Exemptions from the Proxy Rules for Proxy Voting Advice Dear Ms. Countryman: I am a teenager who has held two summer jobs as well as a year-round job as a grocery courtesy work bagging groceries and wrangling carts. I am a member of the United Food and Commercial Workers union. As you know, my generation already has it hard economically, and I am even more concerned for the future. Right now, I have small Roth IRA. While I likely won’t qualify for a pension at my grocery job because I will go to college, people with whom I work will rely on their pensions and Social Security to live once they retire from their jobs. I do not have confidence that Social Security will be solvent when I reach retirement age in decades so I will be reliant on my Roth IRA for retirement income and other investment income I may save over my lifetime. For both me and my colleagues at work, it is critical that our retirement funds be managed to maximize financial returns and not be unduly influenced by proxy advisory firms who do not have fiduciary requirements. It is disturbing to me that proxy advisory firms have also focused on ideological and political issues instead of securing the best possible financial returns. Based on proxy recommendations, some investment funds underperform when measured strictly on financial criteria. The proxy advisory firms are also largely unregulated, yet some have bragged about being a type of regulator themselves. If we want political change, the way to do it is at the ballot box, not by misappropriating money that belongs to others, particularly to those of us who work for minimum wage. I am really disappointed this has been allowed to continue for as long as it has and hope it is changed. I support your recent decision to subject proxy advisors to anti-fraud rules as that is essentially what is going on here. People invest their money for years believing they will have comfortable retirements, yet their fund managers, on the advice of proxy advisory firms, are not acting in their best interest. I support any or all actions to provide oversight of these firms so that they act in the interests of investors. Thank you for allowing me to share my views. Sincerely, John Erlandson [redacted]