Each of the proposed technical fixes to the rule are supportive of the interests of investors and issuers in having clarity and predictability about the rules, and would ease proponent concerns about whether limited company actions on the subject matter of a proposal, or the filing of a prior proposal with very different means or objectives, may block a proposal. The minimal added cost associated with including a few additional proposals on proxy statements is substantially outweighed by the benefit of bolstering investors’ voices and choices in addressing critical issues facing their companies.

We urge the Commission to consider the following economic benefits associated with the proposed rule changes:

Supporting the rights and responsibilities of investment fiduciaries, including pension funds, to assess and manage risk in their portfolios, including long-term risks associated with issues raised in shareholder proposals;

Providing greater choice and flexibility to voting investors in possible approaches to addressing critical issues facing their companies;

Allowing investors to address the portfolio-wide risks posed by issuer activities associated with systemic issues and externalities;

Providing recourse for investors concerned with potentially misleading statements or commitments by

Shareholder proposals often provide the least costly and most efficient means of confirming whether a company’s net zero by 2050 or diversity commitments are backed by actions and metrics, and therefore provide critical information to the market;

Reducing costs of the no action process and increasing efficiency for proponents and issuers alike, including the amount of SEC staff deliberative time on the three exclusions.

The Proposed SEC Amendments to Shareholder Proposal Rule: A Comment from Shareholder Rights Group