From: Todd Davis [todd.davis@chicagoasset.com] Sent: Wednesday, October 02, 2002 2:15 PM To: rule-comments@sec.gov Subject: (s7-36-02) VIA ELECTRONIC MAIL (rule-comments@sec.gov) AND U.S. MAIL October 2, 2002 Mr. Jonathan G. Katz Secretary Securities and Exchange Commission 450 Fifth Street, NW Washington, DC 20549-0609 RE: SEC File No. S7-36-02 Dear Mr. Katz: On behalf of Chicago Asset Management, I am pleased to respond to your recent request for comment on SEC File No. S7-36-02 regarding Mutual Fund Proxy Voting Disclosure. Chicago Asset Management is a leading registered investment advisor founded in 1983 that manages over $1.2 billion for institutional plan sponsors and high net worth individuals. In addition, we serve as the investment advisor to the Chicago Asset Management Value Portfolio (the symbol is "CAMEX"). As a capital steward for plan sponsors, we feel that it is our duty to disclose our firm's proxy voting policies, procedures and our actual votes cast. We are strongly encouraged by your recent proposal that would require mutual funds to report this important information. Any failure of this proposed submission is a complete failure in the battles of protecting the assets and rights of the trillions of dollars invested by the American public and by the Plan Sponsors responsible for the management of these assets. In conjunction with our duties under ERISA, we feel that such a proposal is in support of the disclosure required for Trustees and Directors to properly execute their fiduciary duties in which they are entrusted. In light of the recent fraudulent activities that have damaged the trust of the capital markets, we believe that this proposal is one of the steps needed to ensure that individual investors, plan sponsors and trustees are aware of the policies and procedures of the organizations in which they entrust their assets. Recent comments from organizations in our industry have stated that the cost to provide this information is excessive. Please let me assure you that this is not the case; this information is readily available from an investment management organization. In addition, these proposals would have little to no effect on the abilities to effectively manage the assets in which we are entrusted. In fact, we believe that an investment manager that is active in the voting of proxies adds additional value to the relationship between its clients and the companies in which the organization invests. Based on this information, Chicago Asset Management is pleased to offer its full and unconditional support for SEC File No. S7-36-02 regarding Mutual Fund Proxy Voting Disclosure. If you have any questions or comments in this matter, please do not hesitate to contact me at (312) 795-4822 or todd.davis@chicagoasset.com. Sincerely, Todd A. Davis Senior Vice President CC: Michael Garland, AFL-CIO Office of Investment William Patterson, AFL-CIO Office of Investment Richard Trumka, Secretary-Treasurer, AFL-CIO Jon F. Holsteen, Chairman and CEO, Chicago Asset Management William W. Zimmer, President and COO, Chicago Asset Management Todd A. Davis Senior Vice President Chicago Asset Management Company 70 W. Madison Street 56th Floor Chicago, IL 60602 (312) 795-8422 direct (312) 372-2800 main (312) 372-8489 fax (630) 292-2913 cellular todd.davis@chicagoasset.com