Jan. 30, 2020
Vanessa Countryman Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: File Number S7-22-19 Dear Ms. Countryman: As an employee of the Scott Township Public Works Department in Pennsylvania, I will be receiving a pension from the Teamsters Union Pension Fund, which as you may know is facing some serious financial challenges. Securing and maximizing my pension is vitally important to me as it will determine my quality of life when I retire. That is why the actions of proxy advisory firms and their impact on my retirement income — is so troubling to me. I am thankful the SEC is looking to hold these companies to greater accountability measures, and am grateful for the chance to weigh in on this important issue. For public sector employees, our pensions are often the greatest benefit we gain for the jobs we do—and it is one of the benefits we are careful to protect during collective bargaining. In essence, our pensions give us a greater sense of security in the long run, often making up for longer hours and lower salaries in the short-term. But in order for this strategy to pay off, those in charge of managing and growing our pensions should be making decisions that will maximize investments—and that is not what is currently happening. Rather than recommending financial decisions based on the best interest of investor’s retirement security, proxy advisory firms are all too often steering investment fund managers to make decisions based on a number of social, environmental, or political policies. Quite frankly, politics should not be a consideration in any investment decisions, especially when using these policies as a guide for investing has been shown to produce nearly 44 percent less than standard investment practices. Furthermore, proxy advisory firms have operated unchecked for far too long. Just two of these firms control almost the entire market, with little to no oversight or accountability measures. It is alarming that the pension investments of millions of public sector workers are in the hands of companies that are more concerned with political and social causes than with maximizing financial performance for pensioners like me. There is a time and place for politics—not when you’re supposed to be growing pensions for hardworking folks by making smart investments. Thank you for looking into this matter, and please continue working to bring some much-needed oversight and accountability to the proxy advisory industry. It is absolutely vital that the SEC ensure these companies are acting in the best financial interests of hardworking Americans rather than pushing their own political or social agenda. Sincerely, Jude Scumaci