Committee on Investment of Employee Benefit Assets
June 13, 2003
Jonathan G. Katz
Re: File No. S7-10-03
Dear Mr. Katz:
The Committee on Investment of Employee Benefit Assets (CIEBA) welcomes this opportunity to comment on the Security and Exchange Commission's (SEC) "Notice of Solicitation of Public Views Regarding Possible Changes to the Proxy Rules." CIEBA is the voice of the Association for Financial Professionals on employee benefit plan asset management and investment issues. CIEBA members represent 120 of the nation's largest corporate pension funds, managing more than one trillion dollars on behalf of sixteen million plan participants and beneficiaries.
As the fiduciaries for many of the largest corporate pension funds in the United States, CIEBA members recognize that sound corporate governance practices are important to individual shareholders as well as the overall health of financial markets. CIEBA is supportive of changes in law, regulation and listing standards that have imposed significant new requirements for corporate directors with respect to their independence and qualifications.
In light of the important and changing role of corporate directors, CIEBA urges the Commission to proceed judiciously before proposing major changes to proxy rules and regulations related to their nomination and election.
Further, we urge the SEC to consider the following criteria when reviewing possible changes.
CIEBA appreciates this opportunity to submit our general views on possible changes to proxy rules related to the nomination and/or election of corporate directors. If you need further information or have questions, please contact Judy Schub, CIEBA's Managing Director at (301) 961-8682.