VEA Chair Robert A.G. Monks and Vice Chair Nell Minow have filed a comment with DOL/EBSA on the proposed rule covering proxy voting and ESG factors for pension fund fiduciaries. We strongly endorse the rule, point out the conflicts and deceptions of those supporting the previous rule, and discuss the collective choice problem as it applies to exercise of share ownership rights, the importance of overcoming commercial conflicts of interest, and the challenges and opportunities of increased interest and disclosure of ESG data.