Subject: Shareholder rights (sn# 527)

Nancy Morris, U.S. Securities and Exchange Commission

September 29, 2007

Dear Nancy Morris, U.S. Securities and Exchange Commission,

I am not only a union member concerned about my pension's viability, but also an individual invester who was hurt by the corporate financial "games" played by many company CEOs and CFOs trying to make their books look good or match wall street expectations. I believe the SEC evolved into an advocate and defender of the investing public over the years as well as a regulator.

However in two proposed options for shareholder proposals and director elections it would appear to undermine investor rights. One would take away shareholders rights to file proxy access proposals. The second would set the bar for proposals too high, effectively blocking long term shareholders from the proxy ballot.

The costs of not allowing shareholders to act as owners are great. Enron and WorldCom hurt the economy, hurt workers and hurt retirement funds. Shareholders' ability to nominate directors would take power away CEO-dominated boards and give it back to a company's owners--its shareholders.

I urge you to reject both proposed rules for shareholder resolutions and the election of directors.

Sincerely,
NELSON SULLIVAN

cc:
Senator Charles Schumer
Representative Thomas Reynolds
Senator Hillary Clinton