September 25, 2007
I am an individual invester and I am writing regarding the proposed amendments to Rules 14a-2, 14a-6, 14a-8, and Schedule 14A and 13G under the Securities Exchange Act of 1934, and the proposed new rules 14a-17 and 14a-18.
Let me first say, however, that I find it appalling that the SEC has issued these amendments and proposals as open ended questions and not specific proposals. That is a squishy and suspect way to propose changes to very concrete rules and procedures, and proposed amendments should be presented exactly as intended so that the public can know exactly what to expect.
Most of the proposed amendments are clearly intended to block out shareholder access. The SEC should be taking steps to preserve meaningful proxy access for shareholdes, not undermining it. The proposed changes and new rules would directly and indirectly limit shareholder access by establishing barriers and placing unreasonable reporting and ownership requirements on shareholders wishing to proxy.
I oppose allowing companies to opt out of the shareholder proxy process.
I oppose raising the resubmission rates.
I support allowing increased use of shareholder forums and chat rooms to facilitate communication between shareholders, but I strongly oppose any rule that would allow companies to replace existing requirements for submitting proxies with them.
I support increasing the word limit allowed under Rule 14a-8.