From: Amber Malley [amalley@copera.org]
Sent: Tuesday, June 10, 2003 5:18 PM
To: 'rule-comments@sec.gov'
Subject: S7-10-03

June 10, 2003


Mr. Jonathan G. Katz
Secretary
Securities and Exchange Commission
450 Fifth Street N.W.
Washington, DC  20549-0609

Re:	S7-10-03

Dear Secretary Katz:

The Colorado Public Employees' Retirement Association ("Colorado PERA") is a
public pension with over $25 billion in assets, and is responsible for
providing benefits to over 335,000 public employees, retirees and
beneficiaries.  In addition, Colorado PERA is a long time member and
supporter of the Council of Institutional Investors, and we join our
colleagues in responding to the Notice of Solicitation of Public Views
Regarding Possible Changes to the Proxy Rules issued by the Securities and
Exchange Commission ("Commission") on April 14, 2003 (Release No. 34-47778;
File No. S7-10-03).

At the outset, we commend the Commission for its decision to review the
proxy rules and regulations.  It is encouraging to Colorado PERA that the
Commission is reviewing the current procedures and is willing to formulate
changes and interpretations to improve corporate democracy.

As a public pension fund charged with fiduciary responsibilities to
represent the interests of its public employees, retirees and beneficiaries,
Colorado PERA is an active participant in corporate governance.  Because the
proxy voting process is an integral and important aspect of investing, it is
an area of great importance and concern to us.  Therefore, we strongly
believe that the proxy voting process, including, but not limited to, the
corporate director nomination process, election of directors, solicitation
of proxies for director elections, contests for corporate control,
shareholder proposals, and disclosure requirements imposed on large
shareholders and groups of shareholders should be modernized and streamlined
to allow shareholders greater access.

On behalf of Colorado PERA, our public employees, retirees and
beneficiaries, we applaud your actions, appreciate the opportunity to
provide our comments and encourage the Commission to adopt meaningful
changes to the proxy voting rules and regulations. 

Sincerely,

 <<...OLE_Obj...>> 

Meredith Williams
Executive Director
Colorado Public Employees' Retirement Association