January 29, 2020
Dear Ms. Countryman,
The SEC was founded to protect shareholders and investors from the self-dealing that characterized the early 20th century and triggered the Great Depression.
The proposed changes to Rule 14a-8 stand in direct contradiction of the SECs stated purpose: to protect investors. Ultimately, they would put more power into the hands of CEOs and corporate boards, weaken shareholder protection, especially for smaller investors and diminish basic transparency and corporate accountability.
They serve as an effective form of corporate voter suppression to disenfranchise investors who seek to actively engage with companies on ESG matters, climate risks, sustainability and long-term value creation.
If the SEC intends to adhere to its 2018-2022 Strategic Plan, it must not adopt these rules if it is to meet its first goal, to: Focus on the long-term interests of our Main Street investors.
Main Street investors need a voice, and shareholder resolutions provide it. Long-term interests of investors include concerns about climate change and social risks, which have very real costs that go uncalculated without pressure from individual shareholders.
Thank you for your consideration.