Feb. 2, 2020
Vanessa Countryman, Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-0609 Re: File Number S7-22-19 2/02/2020 Dear Ms. Countryman: Pension funds are being seriously mishandled, and I am afraid most investors do not even realize the extent of the damage being done. Proxy advisers should be sorting through proposals to be voted upon at shareholder meetings and advising fund managers how to vote. This should be a way to allow fund managers to give due time and attention to the finance side of things, without the distraction of corporate governance details. Fund managers, however, have made a habit of “robo-voting,” accepting all proxy advisor recommendations at shareholder meetings no matter what impact these recommendations may have on the performance of a fund. Unfortunately, the impact of many of these recommendations is negative. The recommendations tend to reflect a political agenda, not a fiscally responsible one, and investors who have put their trust and their futures in the hands of their fund managers are the ones who suffer. Proxy firms make recommendations in support of political issues as a way to help their large corporate clients make a statement. Elections and editorials in the local paper are how statements are properly made; pension funds should never be used as such tools. When I was elected to the Soil and Water Conservation Board for Orange County, my top priority became to increase environmental awareness within our communities. I believe bringing greater awareness to investors regarding the state and future of their investments is equally vital to the health of our communities. Thank you for stepping into this issue and advancing a new rule that prevents proxy advisors from engaging in “robo-voting.” Very sincerely, Dawn Curtis Orange County Florida