Subject: File No. S7-22-19
From: Faith L. Lowe

January 13, 2020

January 13, 2020

Vanessa A. Countryman, Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609

Re: File Number S7-22-19

Dear Secretary Countryman,

Please accept this letter in support of rules to prevent political activism that costs investors growth in their retirement savings.

I practice law in the Orlando area. I believe in sound regulatory practices in the financial sector. The SECs review of the activities of proxy advisory firms has yielded a proposed rule that makes sense. In addition to operational support, these firms influence investment policy. Often this influence is in the service of the political priorities that may or not reflect the views of the majority of pension and other retirement savings plans participants but too often mean less robust growth. Personally, I am concerned about how proxy firms are using the proxy process to push political and/or social issues which studies have shown could stifle growth in my 401k plan.

The new rules would not curtail the ability of proxy firms to perform useful administrative and advisory roles. The rules would however bring needed transparency and accountability to their actions. As the regulator, the is correct in making sure investors and money managers can identify these firms possible conflicts of interest or if they stray away from responsible money management principles of growth. Anything these firms do that could negatively affect the value of retirement holdings should be out in the open and kept in check consistent with the new rules.

I encourage a timely completion of the rule making process.

Faith L. Lowe, Esq.