Feb. 1, 2020
Vanessa Countryman, Secretary Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 Feb. 1, 2020 RE: S7-22-19 Dear Ms. Countryman: Our citizens have come to expect a secure retirement. Nothing grandiose; just enough funds to live comfortably when they are older and more vulnerable. They trust our leaders to help make this possible. But many decisionmakers at the state level have failed them. Washington state’s state-administered pension plans have accumulated tens of billions of dollars in unfunded liabilities. One factor in this crisis is the rise of proxy advising handpicked by fund managers entrusted with representing public pensioners. The growth in proxy voting advice has been very disruptive to many retirement accounts. What is particularly frustrating is determining why this has been allowed to happen. How did proxy advisors become so powerful, seemingly overnight? What are their priorities? How do they make their decisions? The approach ostensibly known as “environmental, social, and governance” investing has consistently underperformed; by one account, ESG delivers 43 percent less than the S&P. We need to shine a little light on proxy advising, and I think the S7-22-19 work you are doing is a good start to finding some answers and making some adjustments moving forward. Thank you, and please keep up the good work. Sincerely, Bruce Agnew Beaux Arts, WA