United Association of Journeymen and Apprentices
of the Plumbing and Pipe Fitting Industry
of the United States and Canada

General Office File Reference: THP

December 6, 2002

Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

Re: File No. S7-36-02

Dear Mr. Katz:

On behalf of the 325,000 members of our union pension funds, I am writing to express strong support for the Securities and Exchange Commission's recent proposal, S7-36-02, Disclosure of Proxy Voting Policies and Proxy Voting Records by Registered Management Investment Companies. Most importantly, I strongly support those provisions that would require mutual funds to disclose their actual votes cast.

Our members invest both individually, often through mutual funds, and through a variety of benefit plans, including 401(k) plans that offer mutual fund investment options. Like other investment managers that manage our members' pension assets, mutual funds face conflicts of interest in voting proxies that could lead them to vote with management even if such votes are not in the best interest of our members. But unlike our other investment managers-which are required under ERISA to tell us how they vote-mutual funds have until now shielded their proxy voting from investor and regulatory scrutiny.

I commend the Commission for proposing a rule that will end this double standard-a double standard that has allowed mutual funds to turn a blind eye to the kinds of corporate governance failures that have cost our members dearly at Enron, Tyco and WorldCom among others. Mutual funds own roughly 20 percent of U.S. corporate equity, so their proxy-voting power can be instrumental in protecting our members' retirement savings from the consequences of weak corporate governance. The Commission's proposed rule would give investors the information they need to ensure that their mutual funds take this fiduciary responsibility seriously.

I thank you for the opportunity to comment on this proposal on behalf of United Association.


Thomas H. Patchell
General Secretary-Treasurer