December 10, 2019
I urge you to vote against the proposed changes, in order to protect individual investors from corporate executives who seek to enrich themselves.
I invest a little bit of my retirement savings in every publicly listed US company via an index fund. I don't have the time or energy to make sure that the executives of the companies I own behave responsibly. Instead, I rely on the fund manager to appropriately vote on my behalf, assisted by professional proxy advisers.
Proxy advisers make it easier for shareholders and fund managers to present a unified and accurate front when dealing with executives. Proxy votes are the only chance that the real owners of a corporation, Mom and Pop shareholders like me, get to reprimand or control the executives who control our portfolio companies. The proposed comment period, among other changes, would make it easier for those executives to avoid responsibility for their actions.
For example, in 2013, proxy advisers (correctly) advised a vote against a massive bonus for Jamie Dimon, the CEO of JP Morgan. They also advised a vote in favor of an independent chairman. Naturally, Dimon criticized proxy advisers and investors like me for getting in the way of his big pay day. His incentives are crystal clear. He will continue to enrich himself at the expense of shareholders unless someone, namely proxy advisers, can do the research to rein him in. I obviously can't look at every single company I own to figure out which ones are overpaying executives.
Individual investors are powerless in the face of corporate executive greed unless they band together with proxy advisers to achieve reasonable corporate governance.