Subject: File No. SR-NYSE-2024-35
From: Marianna Cohen

I strongly oppose the SEC's proposed rule change amending Section 302.00 of the NYSE Listed Company Manual to exempt closed-end funds registered under the Investment Company Act of 1940 from the requirement to hold Annual Shareholder Meetings. This is clearly pushed by Blackrock in particular which has been systematically undermining shareholder rights. As matters currently stand, for example, Blackrock manages numerous closed-end funds that trade at a significant discount (ranging by its own admission between ~ 8.7+% (e.g., ECAT BCAT) to 15.47% (BIGZ)) to the value of their underlying assets compared to their peers. And that underperformance is a direct result of BlackRock’s management which has already ensured that no challenges whatsoever succeed by virtue of poison pill provisions already included in the closed end fund governance documents. In other words, Blackrock has no accountability as things currently stand; its defense is purely "trust us - we are the good guys [supposedly] watching out for your interests." The SEC's proposed ill-conceived rule change will only exacerbate this significant problem. The SEC is supposed to protect shareholder rights - -not undermine them. This proposed rule change must be withdrawn.