Subject: File No. SR-NYSE-2024-35
From: John Park

This proposal should never be approved by the SEC. CEFs are very different from open-end funds because CEF capital is locked up for perpetuity. Because of this, CEF managers often behave in ways that are not aligned with what shareholders want. CEF investors have limited options when it comes to holding underperforming CEF management and boards accountable. Annual shareholder meetings provide a platform for CEF investors to express their views and prevent CEF management and boards from entrenching themselves. If the SEC takes away the requirement to hold annual meetings, the SEC would be doing a huge disservice to CEF shareholders and providing an incentive to CEF management and boards to pursue their own objectives with no consequences for their actions. The NYSE is supposed to be a neutral entity. Why is the NYSE proposing this? I think the SEC should dig deeply into this question. I have no doubt that the NYSE was unduly influenced by certain CEF managers (some of whom manage billions and trillions of dollars) who don’t want to address discontent by their own CEF shareholders, most of whom are small investors and don’t have the resources they do. The SEC must reject this proposal.