Jan. 22, 2020
January 22, 2020 Vanessa Countryman, Secretary Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re File Number S7-22-19 Dear Ms. Countryman: I worked for the City of Burbank starting in 1983 and retired in 2010. I spent the better part of three decades working in the Community Development Department, which was responsible for creating and implementation of the City’s rideshare program, as well as city groundbreaking, dedications, and other citywide events. And over the last five years, I served as president of the Burbank Management Association. I am proud of my career and believe I served my community. The entire time, I knew I would be secure for my “golden years.” Now, I am not so sure. Activist investment funds like CalPERS have been relying on proxy voting to intimidate American companies to promote the ideological views of those in power, leading to a $138.9 billion unfunded liability. Fund performance, not political statements, should be the priority in order to fill these gaps, but our leaders believe otherwise. I applaud the SEC’s efforts so far and encourage the SEC to exercise your oversight authority. I am not opposed to corporate responsibility, but there are local, state, and federal governments to impose standards of conduct, not some investment advisor. The proxy advisors believe they are super-regulators, and they intend to use the funds of others to regulate legitimate American businesses. Is that democracy? Did anyone vote for these people to be regulators? Given their own problems with transparency and conflicts of interest, perhaps they should focus on their fiduciary duties instead of righting what they perceive to be society’s ills. If we had overflowing pension funds, and pensioners could decide individually how much of their pensions they wanted to give to these causes, then that would be fair. But the decision-making process of proxy advisors does little to engage CalPERS members and the fund is upside down. They see us as political pawns to be exploited for their own ends, and it is very frustrating as a recent retiree. I can’t make plans for my future because I don’t know how much, if any, of my funds will be there in 10, 20, or 30 years. I hope you will apply proper regulations on the proxy advisory industry, which is really just two firms. Working Americans need their pensions protected. With Regards, Ellen Knapp Sent from Mail for Windows 10