November 8, 2019
Objections to proposed rules 34-87458 and 34-87457, S7-23-19: 1. The rule, 34-87458, requiring greater stock ownership in order to make a proposal is discriminatory and violates the rights of small shareholders. Furthermore, this rule will hurt corporations in the long run. This rule has been proposed for no reason other then the desire of corporate management to silence the voice of small shareholders, yet it is this voice which looks to the future, not the short-term profits. Corporate management has voted itself huge bonuses and payouts based on corporate earnings, even if those earnings are at the expense of quality, safety, and the environment. There is a conflict of interest between corporate management and the small shareholder who wishes to have a future investment and see the corporation thrive in the long-run. Corporate management has shown a pattern of taking quick profits now so they can get their bonuses, laying off employees even at the expense of product quality, buying back stock instead of investing in corporate development. They do not take the long view because it is in their interest to make a quick profit. Unlike the current management, the small shareholder is concerned about the future of the company, its continued viability, and the safety of the community and the environment in general. To impede the ability of the small shareholder to protect the future of the corporation and protect our environment is short-sighted and counter-productive. Corporate management needs the small shareholder proposals to adjust corporate policy for the long-run view. And of course, as stated in the opening, the rights of those without large sums of money to invest in one corporation will be discriminated against, which is unlawful under the 14th Amendment. 2. Rule 34-87457, requiring further procedures for "accuracy" for submitting proposals, gives the power to rewrite and delay proposals to the very people who oppose them. This is also a violation of due process and the 14th Amendment. The rule is unnecessary and again is to give more power to corporate management while removing it from the small shareholder. Please do not pass these rules. Thank you, Denise Noah [redacted]