December 4, 2019
Sirs: I seek to grandfather in the eligibility for shareholder proposals of 3 years stock ownership: “However, the proposed amendments would require that, in order to take advantage of that ownership threshold, a proponent must have held the shares for at least three years in order to demonstrate long-term investment in the company.” [Press Release, “SEC Proposes Amendments to Modernize Shareholder Proposal Rule,” FOR IMMEDIATE RELEASE. 2019-232] https://www.sec.gov/news/press-release/2019-232 For instance, I have held stock in Citicorp for over a year prior to the shareholder meeting, but Citi feels that it is insufficient. Citi wanted a year prior to submitting a proposal, which is intended to delay my proposal. Regards, Peter Lindner [redacted] [redacted] cell: [redacted] home: [redacted]