Subject: File No. S7-22-19
From: Shauna Farries

January 9, 2020

January 9, 2020

Ms. Vanessa Countryman, Secretary
Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-1090

Re: File Number S7-22-19

Dear Secretary Countryman:

I am writing with a comment on an issue coming before the Securities and Exchange Commission. It feels like a complicated issue at first, but once you realize it affects millions of Americans, I think you start to understand it pretty quickly. Ive recently been following the news of major public pension funds choosing to divest from stocks that are socially unpopular, whether its gun manufacturers, tobacco, and the like. I can understand this inclination, but these types of sweeping financial decisions on behalf of millions of American pension plan recipients seems flagrantly irresponsible.

Considering that point, I looked into it and found that proxy advisory firms are the groups responsible for guiding the investment strategies for public pensions. Not only that, but only two of these types of firms are responsible for the proxy investments of nearly every public retirement fund in the United States. That means theres just a handful of activist investors potentially steering pensions off a cliff, and all in the name of being politically correct.

Before you accuse me of being too political myself, keep something in mind—I work with Tobacco Free Kids. I have dedicated my career to ensuring our children grow up to be the first generation that doesnt touch tobacco products. I can certainly sympathize with groups who wish to see pension funds divested from companies like these, who have harmed so many, including innocent children. However, despite my personal feelings, I understand the importance of disassociating my political leanings from whats in the best interest of the retirement savings of countless others (many of whom do not share my passion on this subject).

I dont participate in a public pension, but you can bet if I found out that my current 401k plan was behaving in such a manner I would have something to say about it, and I can only imagine how the public employees counting on CalPERS or similar plans must be feeling. I hope youll take my thoughts on this subject into consideration. I look forward to hearing next about proxy advisory firms when their ability to act in this manner is put to rest once and for all.

Best Regards,

Shauna Farries
Tobacco Free Kids