SEC Proposed Rule:
Disclosure of Proxy Voting Policies and Proxy Voting Records by Registered Management Investment Companies
Proxy Voting by Investment Advisers
[Release Nos. 33-8131, 34-46518, IC-25739; File No. S7-36-02] File No. S7-36-02]
[Release No. IA-2059; File No. S7-38-02]
The following information using Type Letter D was submitted by 8 individuals.
Subject: Proxy Voting
Mr. Jonathan G. Katz
Securities and Exchange Commission
450 Fifth St., VW
Washington, DC 20549-0609
Re: Proposed Rule S7-36-02 (Proxy Voting by Mutual Funds)
Dear Mr. Katz,
As a mutual fund owner, I am writing in support of the SEC's proposed rule requiring mutual funds to disclose their proxy voting policies and voting records.
Mutual funds represent a powerful force in today's markets and have a strong moral and legal responsibility to participate in the governance of corporations they own on behalf of their customers. These corporate governance decisions have important implications for the economy and for the economic security of millions of fund holders across the country. We are presently witnessing the tragic fall-out from a lack of attention paid to corporate governance issues. I expect my mutual fund managers to invest my funds and vote the funds' proxies in ways that promote my economic security and well being. I also expect my mutual fund managers to provide their investors with easy access to the decisions that they have made regarding their proxy votes and policies whether by links on their websites or traditional printed disclosures. The proposed rule would go a long way toward increasing the transparency of mutual fund proxy voting practices and assure that mutual funds' performance in corporate governance can be scrutinized.
One of the arguments the fund industry makes in opposing this proposal is increased cost. The mutual fund industry spent $266 million and $356 million on advertising in 2001 and 2000 respectively. Most of these advertising funds come from shareholder fees. Diverting a small portion of these advertising revenues to enhancing corporate governance performance and reporting would greatly enhance shareholders' investments in their mutual funds.
I appreciate the SEC's leadership in proposing this rule and hope the Commission will adopt a final rule without substantial changes.