October 19, 2010
The Honorable Mary L. Schapiro
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Thank you for the opportunity to comment on the SEC July 2010 Concept Release relating to proxy mechanics reform.
The current proxy system should be reformed to minimize the fees paid by issuers in connection with the distribution of proxy materials while maintaining a proxy distribution system that is efficient, reliable and accurate. A system that allows a competitive fee structure and real competition should result in lower costs and better service to public companies. Additionally, the system should be reformed to facilitate more meaningful shareholder communications and increased voting participation.
Vice President, Corporate Affairs
& General Counsel