SEC Proposed Rule:
Disclosure of Proxy Voting Policies and Proxy Voting Records by Registered Management Investment Companies
[Release Nos. 33-8131, 34-46518, IC-25739; File No. S7-36-02] File No. S7-36-02]
The following information using Type Letter J, or variation thereof, was submitted by
Subject: Proxy Voting Policies and Records
Form Type Letter J:
I am writing in support of the SEC's proposed rule (File No. S7-36-02) to
require mutual fund companies to disclose how they vote on corporate proxy
resolutions, which often deal with issues of concern to me. I want to know
how my mutual fund is voting on issues related to:
Executive compensation programs,
Board make-up and independence,
Gender discrimination, and
Other important issues that matter to me.
The recent wave of corporate scandals provides ample evidence that corporate
America need greater transparency, responsibility and accountability.
It is estimated that mutual funds, which represent about 90 million
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
there is no way for me to know/verify whether the manager of my mutual fund
acting in a manner that reflects my best interests as an investor. As a
fund shareholder, I want potential conflicts of interest exposed. I want to
know what principles will guide the mutual fund in determining how it votes
corporate proxy contests.
I believe that as an owner of mutual funds, that I am entitled to know how
proxy is being voted. I urge the SEC to stand up for investors and for
accountability and to vote in favor of the proposed proxy voting rule.
I cannot emphasize enough how deeply this issue affects me in my investment
decisions. My confidence in the markets has been so shaken that I have not
made any further investments in specific equities and I am critical now of
how my mutual funds are being managed and used to intentionally or
unintentionally continue to promote such future scandals.
Despite the argument by the Mutual Fund industry that disclosure will place
an undue burden upon their businesses due to the shear number of votes they
would need to document and report, it does not supercede the investors
to this information and its influence on an investor's ability to make clear
and fully-informed investment decisions. The SEC should require each mutual
fund firm to product 'Electronic disclosures' of this information; not
the SEC's "Edgar" database for corporate filing disclosures.