Jan. 19, 2020
Vanessa Countryman, Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-0609 Re: File Number S7-22-19 Dear Sec. Countryman, I invest steadily in my personal retirement account and consistently make decisions today that will lead to a secure retirement later, so I appreciate that the SEC is taking steps to safeguard private investments and pension funds by rewriting the rules on the proxy process. At the moment, proxy firms like Glass Lewis and ISS can use investments as de facto weapons to fight ideological battles, by making vote recommendations that prioritize or penalize industries that are aligned or misaligned with these agendas. Investing along such lines has been shown to produce returns that are a lot lower than a standard index fund. The error in prioritizing an ideological statement over solid investment principles is clear. Studies also show that retirement nest eggs will be 10 percent lower in the coming years without a reform along these lines, one that makes explicit that healthy returns should be the priority. The SEC should require that proxy advisory firms adhere to high fiduciary standards in making recommendations and influencing the direction of private investments. Thank you, Kevin Carr Pinellas County, Florida