Subject: File No. S7-23-19
From: John Tierney
Affiliation: CPA (inactive) retired partner big four

November 24, 2019

I do not support the proposed changes primarily on the grounds that a shareholder is a shareholder regardless of size of investment ( after all some of the largest investors are simply a lot of small individuals through mutual funds). However more importantly it prevents the ability of a corporation to learn, the size of someones holdings has no relevancy to the quality of ones idea or proposal.