January 22, 2020
I feel that the proposed amendments to Exchange Act Rule 14a-8 will have a negative effect on the ability of legitimate fund managers to present the concerns of their clients to companies that appear in their portfolios. On 14a-8(a): While I grant the issue of changes in market values since the last review, I think your proposed changes go too far. If inflation suggests that the current value of $2000 is something like $9000 now, I would say the change to $25000 is too much. And the change to the years-held requirement will serve as a barrier to funds that acquire a stock and then are prohibited from submitting proposals because they have not held the stock for 3 years. Three years is a long time to have to wait to make concerns known. On 14a-8(b): I submit that you have not shown a need for your proposed amendment to this part of the rule. However, if you insist on requiring fund managers to present documentation of their clients' agreement with their representation, make it a one-time consent. I join a fund because I have confidence and trust in the managers. If I give a one-time consent to them representing me when submitting proposals on my behalf, that should be good enough for you. Requiring separate forms for each proposal will result in undue costs to the fund, which will affect the performance of my investment. That is unacceptable. Thank you for your consideration of these comments.