Subject: File No. SR-NYSE-2024-35
From: Ray Meadows CPA, CFA, MBA

My firm specializes in closed end fund investing. Such funds commonly trade away from net asset value for various reasons. Discounts are larger for poorly managed funds and this provides an incentive for activist investors to seek control of the fund and drive the discount down to more reasonable levels by better management or through tender offers or even liquidation. In this way shareholder returns are enhanced and shoddy managers are eliminated or at least incentivized to do better. The proposal is likely to reduce market discipline and reduce returns to my clients. I therefore oppose the proposal.