January 5, 2020
Dear Sirs:
I see little to no justification for your proposed rule changes in corporate governance, S7-23-19. In fact, I would advocate strengthening shareholder rights, rather than weakening them.
Our history is littered with examples of corporations acting badly, so facilitating the ability of boards of directors or senior executives to ignore the wishes of the owners of a corporation is foolish. It is often the case that the collective wisdom of the public is superior to the thinking of a small clique with narrow interests.
I am particularly opposed to the requirement that a shareholder or a person be allowed to only submit a single proposal per shareholders meeting. There is absolutely no justification for this. A person may have two unrelated proposals, which may benefit the shareholders if adopted. In that case, why should they have to wait a full year after the first proposal is submitted to put the second one forth? Rather than the proposed rule change, I would abolish this part of the rules altogether. The idea that if someone other than me submits more than one proposal, it somehow limits my rights, is absurd.
Thank you for considering my views,
A. G. Gash