Subject: File No. 4-537
From: William Michael Cunningham, MA, MBA
Affiliation: Social Investing Advisor, Creative Investment Research, Inc.

May 11, 2007

Comments on the SEC Proxy Process Roundtable

Summary

Current proxy processes and regulatory limits to filing nonbinding shareholder proposals were designed in an era where manufacturing was dominant. In that environment, limiting the ability of shareholders to suggest "settings for the machinery" was entirely appropriate. This is, however, no longer the case.

We prefer the ability of shareholders to put proposals forward be based, in part, on length of share ownership. Further, to eliminate identity fraud and duplicate vote issues, we suggest the creation of a unique, time sensitive share and holder identifier. The ability to vote would attach to the identifier and expire after a certain time period.

We believe technology allows for the efficient solicitation of opinions and proxy votes from shareholders, via a secure on-line discussion area. We note that the difference between a "chat room" and a secure on-line discussion area is akin to the difference between a bar and a private conference room. For proxy voting purposes, we prefer the latter.

We previously outlined a procedure for blending in proxy access and XBRL. See:

http://www.sec.gov/news/press/4-515/wcunningham7465.pdf
(See page 17)

We call for the adoption of technology enhanced, flexible proxy voting policies and procedures, based, in part, on market capitalization and the number and average tenure of shareholders.

Finally, we incorporate by reference earlier related comments to the SEC:

http://www.sec.gov/rules/proposed/s71005/wcunningham5867.pdf
http://www.sec.gov/rules/proposed/s70306/wcunningham6601.pdf
http://www.sec.gov/rules/proposed/s71903/wmccir122203.pdf

William Michael Cunningham
Creative Investment Research, Inc.
www.creativeinvest.com

Not for distribution or reproduction. Copyright, WMC and CIRI, 2007.