Subject: File No. 4-583
From: Les Greenberg
Affiliation: Committee of Concerned Shareholders
May 28, 2009
Sir/Madam,I support the proposed amendment to Rule 14a-4(b)(1) for the following two reasons, among others:
The rule change proposed is consistent with other initiatives strengthen the link between the actual votes cast (or not cast) by beneficial owners and the outcome of the shareholder vote on individual resolutions presented to shareholders on proxy forms (where discretionary voting by brokers or banks of fields left blank by beneficial shareholders has historically biased this link in favor of the issuer). It effectively takes away a layer of voting that does not truly reflect the interests of the beneficial owners and which does not exist in civic voting.
The rule change proposed clarifies the existing language of Rule 14a-4(b)(1), limiting alternative interpretations of how to communicate to the beneficial shareholder the effect of leaving a field on a voting instruction form blank where an intermediary transmits the voting instructions.
Les Greenberg, Chairman
Committee of Concerned Shareholders