Jan. 29, 2020
Ms. Vanessa Countryman, Secretary Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 File Number S7-22-19 Dear Secretary Countryman, I am happy to send this letter into your comments on the issue of proxy advisory firms and their role in the investment decisions of public employee pensions, which is currently before the Securities and Exchange Commission. Unlike some others you may be hearing from on this issue, I am not a lifelong public employee. I only started working for the town of Mt. Lebanon Township here in Pennsylvania as a laborer a few years ago. But I am still proud to be a member of the United Brotherhood of Carpenters and Joiners and participate in the pension plan offered to Pennsylvania public employees, the Pennsylvania Municipal Retirement System (PMRS), and I will be counting on my pension as a part of my retirement one day. My pension will not be enormous, largely due to the fact that before I became eligible to participate, PMRS started having financial problems, finding itself enormously underfunded. This is why I have been watching the activities of the fund so closely, and why I have grown alarmed at recent news events involving public employee pensions. When I hear about “activist” investors working on behalf of funds like CALpers to discriminate against certain investments due to “social” concerns, I start to worry. When I learned that these types of political decisions are being made by just a handful of proxy advisory firms, with no input from plan participants, I got a little more concerned, then downright anxious. I do not consider myself an experienced investor, but I think that I know enough to know that if a stock does well and delivers fair returns, there is no reason to exit that investment—particularly when you’re making a decision that affects the retirement futures of thousands of employees. It’s not like public employees are wealthy and can afford to make emotionally driven, impulsive decisions about their investments. For many of us, the pension plan is the only safety net we have for our golden years. Allowing social or political feelings to come into play seems like fiduciary malpractice on the part of the proxy firms. Finally, I am concerned that only two companies are able to control the proxy advisory market for more than 90% of the public pension plans in the whole country. Doesn’t that limit the number of people whose voices can be heard on these critically important decisions? I hope you’re hearing from a wide range of citizens on this issue, and that you’ll take the opinions of average employees like me under consideration. I appreciate your time reading my comments. Sincerely, Jarett Frank