From: Patrick Christensen [ptc2@surfbest.net] Sent: Thursday, November 21, 2002 5:55 PM To: rule-comments@sec.gov Subject: FILE NUMBER S7-36-02 and S7-38-02 Dear Mr. Katz, I am writing to express my formal support for the proposed SEC rules requiring greater disclosure of proxy voting practices by mutual funds and investment advisers. There are a number of reasons why this will be good for individual investors. First, investors have a right to the information. Mutual fund investors and investment advisers have been requesting greater transparency at the corporate level for years. It is time they provided their shareholders the same transparency. Recently, I was trying to help a socially responsible investing client determine how a certain fund voted its proxies. Unfortunately, I could not obtain that information. With the proposed rule in effect, it will be possible for me to obtain this information and thereby better serve my clients. Second, disclosure of information holds investment companies and managers accountable for their behavior-both financially and socially. If a company votes proxies in a manner that hurts society, they should be accountable. Likewise, if a company doesn't pay attention to the proxies it is voting and as a result the company's management or the board of directors goes too far afield, the investment company will have to answer for their lack of oversight. Third, knowing that someone is monitoring their voting records will prevent investment companies from putting their own interests ahead of their clients' interests. (For example, if a mutual fund company is trying to win a bid to manage a firm's 401k, they might be inclined to vote in accordance with management so as to not lose the deal. However, if they know shareholders will review their voting record, they might think twice.) Fourth, if administered properly, the cost to mutual fund companies and investment advisers should be very inexpensive. I would advocate that companies merely list this information on their Website. It would be wasteful to send it to each individual shareholder because many won't be interested. Thanks for your consideration. Sincerely, Patrick T. Christensen, MBA, CPA, CFP Independent Financial Solutions LLC 2505 East 3300 South, Suite 301 Salt Lake City, UT 84109 (801) 487-4536 (phone) (801) 487-6272 (fax) www.ifs-llc.net