From: dragonlakegs@shaw.ca
Sent: Saturday, November 09, 2002 11:58 PM
To: rule-comments@sec.gov
Subject: File No. S7-36-02



Dear SEC Secretary,

I support the SEC's proposed rule to require mutual fund companies to disclose 
how they vote on corporate proxy resolutions.

Now that the folly of investor greed has risen in the consciousness of most 
investors we realize that the game of selling to a greater fool is over.  We 
cannot expect to advance our investments on a frothy wave of overvaluation 
that numbs us to the self-serving behaviour of corporate executives and incestuous 
auditors.  So many of us thought this was OK (what little we actually knew of it) 
as long as we got our share.  Now it is clear that management of corporate America 
needs greater transparency, responsibility and accountability to the shareholders, 
the true owners.  It is estimated that mutual funds, which represent about 90 million 
Americans, account for 20 percent of proxy votes at corporate shareholder meetings. 
As such, mutual funds can play a major role in insisting on more responsible behavior 
on the part of publicly traded companies.
 
In the absence of public disclosure of proxy policies and proxy voting records, there 
is no way for me to know whether the manager of my mutual fund is acting in a manner 
that reflects my wishes.  As a mutual fund shareholder, I want to know how my mutual 
fund is voting on issues related to executive pay, board make-up and independence, 
dividend payout and other issues that matter to me.  I want potential conflicts of 
interest exposed.  I want to know what principles will guide the mutual fund in 
determining how it votes in corporate proxy contests. 

I believe that as an owner of a mutual fund, I am entitled to know how my proxy is 
being voted. I urge the SEC to stand up for investors and for corporate accountability 
and to vote in favor of the proposed proxy voting rule.

Why don't you also give some thought to introducing another rule, mandatory dividends?  
Think of the benefits that a rule compelling companies to distribute the profits to 
shareholders, unless the shareholders vote otherwise.  That would impose a huge amount 
of discipline on the accuracy of reported profit numbers.  Any management team that 
thought that it had an attractive use for the profits (re-investment, acquisition, 
etc.) would be required to put the proposal to a shareholder vote.  If the true 
owners of the company (and the profits) were not convinced of the plan, the hired 
hands (management team) would have to distribute the profits.  Naturally, the mutual 
funds exercising proxy votes would also have to follow the wishes of the fundholders.  
Another reason for supporting the current SEC proposed disclosure rule.

Thanks for your time.

Greg Strebel

Greg Strebel

3641 Hydraulic Road

Quesnel, BC 
V2J 6G4