Treasurer of State
State of Maine
Office of the Treasurer of State

39 State House Station
Augusta ME 04333-0039
207.624-7477 (voice) 207.287-2367 (fax)


December 22, 2003

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

Re:  File No. S7-19-03
Security Holder Director Nominations

Dear Mr. Katz:

I am writing in support of the Securities and Exchange Commission's proposed rule concerning Security Holder Director Nominations (34-48626). The SEC's proposed rule serves the best interest of all investors, large and small and I commend you for taking action. However, I urge Commission to strengthen the rule according to the recommendations of the National Coalition for Corporate Reform (NCCR).

Specifically, with regard to proxy access triggers, I request that the SEC strengthen proposed triggers and add additional triggers:

I stand with the NCCR on these issues as well:

These enhancements to the rule you have proposed will, I believe, strengthen American corporations and safeguard shareholder value.



S/Dale McCormick

Dale McCormick
Maine State Treasurer