Dear Chairman Atkins and Commissioners Peirce and Uyeda,

We write as retirees, pension beneficiaries, and individual and institutional investors whose savings depend on the integrity of America's capital markets. We urge you to preserve the shareholder proposal rule as a cornerstone of property rights and free-market accountability.

Shareholder proposals are an expression of ownership. For eighty years, the ability of shareholders to raise questions before the companies they own has been one of the most effective free market-based checks on corporate mismanagement. The need for regulators to intervene is reduced when owners can speak directly. That is the genius of the system — and precisely what is at risk.
Shareholders have advanced sound governance of their companies through decades of governance reforms, adopted first through the shareholder proposal process and then as general market practice.

When investors ask a clothing retailer to account for supply chain vulnerabilities, they are protecting brand equity and long-term profitability. When they ask a pharmaceutical company to address legislative risk embedded in its earnings guidance, they are doing the analytical work that sound investing requires. When they flag water scarcity exposure for agricultural, beverage, semiconductor, or mining companies, they are surfacing risks that conventional financial filings routinely omit — risks that eventually become losses borne by ordinary shareholders.

Other investors have a right to inquire whether environmental or social commitments of a company are undercutting shorter term profitability. Regardless of the time horizons of investing, this is a critical right of investors to engage a fundamental American value — the marketplace of ideas.

If the shareholder proposal process is curtailed, the practical result is not quieter markets. It is a transfer of power: away from diverse owners, and toward a narrow class of the largest institutional players. Smaller investors — retirees, pension funds, individual savers — will lose one of the only shareholder protection tools scaled to their resources. Blind spots will accumulate. Risks that could have been surfaced early will compound, spreading across companies and sectors until they become systemic.

The boards and executives of public companies should answer to their owners. That principle is not progressive or conservative — it is foundational to capitalism.

We urge the Commission to honor its mandate to protect investors and maintain fair, efficient markets by keeping this rule intact.

Let America's public companies be guided by their shareholders — not shielded from them.