RCG E-Mail Stationery StationeryFrom: Jim Rodeghero [jim@earth-hq.com]
Sent: Thursday, December 26, 2002 5:51 PM
To: rulecomments@sec.gov
Subject: Mutual Fund Proxy Rules (s7-36-02)

Importance: High
Sensitivity: Confidential

Sir/Ms:

 

I am absolutely 100% in favor of broadly expanded disclosure by mutual 
fund management companies.  Their rationale for not disclosing fund 
holdings, cost/expense detail, and proxy votes is completely self-serving 
and demonstrates the exceptional conflicts built into their operations.  
The conflicts are at least as egregious as those in the investment banking 
business and you must move quickly to address this issue.  Too many Americans 
have their life savings invested in mutual funds to allow the managers to 
operate in secrecy and avoid disclosure of their proxy votes.

Simply put, they do not want to be forced to disclose their votes for one 
reason only:  they want the pension management accounts from the companies 
in which they invest and they know that they will lose that lucrative business 
if they vote the shares in the best interest of the fund shareholders.

You can fix this problem and you should.  Stop playing politics and do the 
right thing.

 

James A. Rodeghero, Ph.D.