Jan. 26, 2020
Secretary Vanessa Countryman Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 RE: File Number S7-22-19 Dear Sec. Countryman: Thank you for reviewing the proxy advisory industry and soliciting comments from the public on this matter. I am providing my personal view as a marketing manager for an environmental solutions company. I care deeply about environmental issues and leaving a better planet for my children, but I have serious concerns about the proxy advisory process. Obviously, one of the top concerns of this industry is the “environmental, social, and governance” investing strategies used by many proxy advisors. This approach was likely well intended at first, and it is not completely unwarranted. Certainly, investment managers should be conscious of ethical concerns, including environmental issues. But ESG investing in practice has undermined legitimate, law-abiding companies and standard corporate governance, so I believe it requires greater oversight. The current system exacerbates ESG overreach through redundancies due to the duopoly of only two firms who control nearly the entire industry, as well as several questionable techniques like automatic voting that takes one decision and replicates it over numerous decision-making platforms. There is also little transparency into the process; more insight are clearly needed to ensure the process is fair-minded. I would prefer that greater oversight be issued over these firms and their influence. I fully support the SEC’s guidance issued in August on this issue. Sincerely, Keith Adams . [redacted]