Annual shareholder meetings continue to have a vital function in ensuring greater efficiency and shareholder value for closed-end funds in several ways. They ensure greater accountability, transparency, and the opportunity for management to receive vital feedback for shareholders that they can then use to determine whether changes, modifications, or deviations from the fund’s current strategy and tactics. CEFs operate more like companies than open ended funds in this respect. One clear example is the use of share buybacks and tender offers to ensure the fund’s pricing does not fall too low below its NAV; these tools provide significant shareholder value but are not in the interests of management in most cases. As a result, they are underutilized among CEFs. The mechanism of the annual meeting provides shareholders an opportunity to confront management if their avoidance of these mechanisms is more for their own interests than that of the shareholders. The majority of CEFs are held not directly by retail investors but through intermediaries, particularly wealth managers, who themselves often have misaligned incentives that fail to protect the interests of CEF shareholders. As a result, actual CEF shareholders’ interests are already underrepresented in elections because very often those shareholders trust wealth managers to vote alongside their interests, but the wealth managers are lobbied to vote alongside institutional investor interests, oftentimes those interests clash with CEF shareholders. Removing annual shareholder meetings will provide greater power to these institutional investors to act behind the scenes and without transparency, instead of institutional investors bringing their case to actual CEF shareholders. Removing annual shareholder meetings will not only disenfranchise minority shareholders while inserting greater risk into the CEF ecosystem that will alienate some majority shareholders. For both the efficiency of capital markets and the economic interests of shareholders of all sizes, I would suggest not removing annual shareholder meeting requirements from Section 302.000 of the NYSE Listed Company Manual. Finally, i am particularly concerned at the timing of this proposal. With the marketing of a $25 billion CEF, the largest publicly listed CEF in America by a significant margin, and increasing awareness of CEFs after several decades of investor apathy, I fear that changing the requirement for annual shareholder meetings will engender a lack of confidence in the integrity and objectivity of the SEC and NYSE as regulating bodies and particularly in the NYSE’s objectivity as an SRO. While the rule change is a risk to the stability and efficiency of the CEF market, it is also a risk to the reputation of the SEC and of American financial markets.