From: Kenneth Marvel [2CaptMarvel@msn.com]
Sent: Tuesday, March 09, 2004 7:03 PM
To: rule-comments@sec.gov
Subject: S7-03-04:

We are in favor of the proposed SEC rule to require mutual funds' boards of 
directors be chaired by outside directors.  As things are now the chairman of the 
board can either be a top executive of the same mutual fund and/or the investment 
advisory firm the board oversees.  We think this current situation can lead to the 
perception of, if not an actual, conflict of interest for the board chairman.  The 
paramount role of mutual fund boards of directors is oversight of fund management 
and the investment advisory firms hired by the fund.  We believe the interests of 
share holders will be better protected if the board chairperson can only be 
selected from the ranks of the independent directors.

 

While we support this SEC proposal we think more should be done to increase the 
accountability of directors to shareholders.  We recommend that the SEC also 
propose rules that would require annual elections of ALL board members AND that 
funds provide a "user friendly" process for shareholders to place nominations on 
the ballot for electing directors.

 

Sincerely, Kenneth D. Marvel and Terri L. Alexander

6526 170th Pl. SW

Edmonds, WA. 98026