National Integrated Group Pension Plan

December 5, 2002

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

Re: File No. S7-36-02 (Comments)

Dear Mr. Katz:

I am filing these comments on behalf of the Board of Trustees of the National Integrated Group Pension Plan ("NIGPP"). The NIGPP is a multi-employer pension plan composed of over 300 participating employers and over 70,000 active, retired and vested participants. I am writing to express the Board of Trustees' support for the Securities and Exchange Commission's recent proposal, S7-36-02, Disclosure of Proxy Voting Policies and Proxy Voting Records by Registered Management Investment Companies, including those provisions that would require mutual funds to disclose their actual votes cast.

As the Proposed Rule notes, mutual funds hold approximately 20% of all publicly traded U.S. corporate stock, and are in a position to exercise enormous influence in the capital markets and enhance shareholder value. In turn, the enhancement of shareholder value, including the protection of stability and return on corporate securities, affects the financial security of this pension plan and others like it. Your proposal seeks to enhance shareholder value by insuring that the exercise of proxy voting is done in a manner consistent with the best interests of the fund involved and its shareholders. The Board of Trustees of NIGPP supports this effort.

Thank you for the opportunity to comment.


Douglas Evans CEBS
Administrative Manager,
On Behalf of the Board
Of Trustees