Subject: File No. S7-30-10
From: Adrienne Brown, MBA
Affiliation: Nationwide Investment Management Group

November 18, 2010


In regards to the timing of the NPX filing, I would suggest that it be pushed back from August 30 to a later date such as September or October with the same period of 7/1 to 6/30. Attempting to compile the number of shares votes vs the number of shares held at the time of a 14A disclosure will be time consuming

Also, would you please clarification in regards to shared votes and who should file vs who should reference if we give proxy voting authority to our sub-advisors? In our case, we have several sub-advisors that have their parent company file the 13F on their behalf, but how exactly should that work in the NPX process?

Please advise and add my email to any other information that the SEC sends out to keep us abreast.

Kind regards,
Adrienne Brown, MBA
Nationwide Investment Management Group
1000 Continental Drive
Suite 400
King of Prussia, PA 19406