Professional LetterFrom: Bannockbrun Securities, Edward Johnson [bbsllc@ameritech.net] Sent: Thursday, December 05, 2002 5:06 PM To: sec Subject: SEC RULE Comment 3 Kenneth N. Flammang 3821 West Sherwin Avenue Lincolnwood, IL 60712-1021 November 7, 2002 Mr. Jonathan G. Katz – Secretary Securities and Exchange Commission 450 Fifth Street NW Washington DC 20549-0609 Subject: File No: S7-38-02 Gentlemen: Please be advised I am: (FOR) A. Rule 206 (4) – 6, and (FOR) B. Rule 204-2 as proposed. Comment: It is imperative that all investment advisors with discretionary authority be held accountable for the preservation and maintance of all documents (i.e.: hard copy, electronic, etc.) used to substantiate their voting positions. It is essential that all interested entities have complete access to the information, as proposed, so there is complete transparency. The proposed rules when enacted will allow for competent investment evaluations to be made based on the voting decisions of the fiduciaries. Sincerely, (Signature) Kenneth N. Flammang KNF/st File: SEC-1-02