The following Letter Type A, or variations thereof, was submitted by individuals or entities on SR-NYSE-2005-67.
Letter Type A:
December 21, 2005
Jonathan G, Katz
Re: Proposed Rule for Paperless Proxy Votes (Release No. 34-52826: File No. SR-NYSE-2005-67; 11/3O/O5)
Dear Mr. Katz,
______________________ is concerned with the Securities and Exchange Commission's proposed rule (FR-34-52826) that would eliminate paper proxy vote results and replace this current process with an electronic system of notification. Under this proposed rule, companies would provide shareholders with annual reports and proxy voting materials online, rather than on paper and offer shareholders the option to receive the information on paper only if requested. As a company that sells printing paper, printing equipment and supplies, is concerned about the negative impacts this proposed rule could have on our industry, as well as the industry's supply chain business, including printers, distributors, converters and others.
The paper products industry, like most other U.S. manufacturing industries, faces significant challenges in the marketplace. __________________________ believes that the proposed rule would represent another difficulty and could lead to further job losses in paper manufacturing, distribution and allied industries. At this moment most of the companies in our industry, including ________________________, are going through significant change and downsizing to realign personnel and installations to put themselves back into a profit mode. The numbers created by your proposal are significant and would have a negative effect on our company and our employees.
Another concern with the proposed rule is that electronic balloting may not be fully utilized by those without internet access and the elderly. Studies show that only 22% of Americans 65 and older use the Internet, therefore more than 75% of elderly shareholders may not participate in the proxy voting process and would not receive their annual reports. Furthermore, consumer research indicates that nearly 45% of Americans rely on the confidence, reliability, privacy and safety of receiving information on paper. As a senior citizen an a stock market investor I can relate all too well to these facts.
One option that could mitigate these concerns would be to offer an "Opt In" program in which shareholders could choose to receive online proxies as opposed to the "Opt Out" process, as proposed in this rule. Under an "Opt In" process, shareholders could continue to receive proxies in paper form and could request to receive the electronic version instead. An "Opt In" program would strike an appropriate balance between reducing costs for NYSE financial companies while minimizing the negative impacts on the paper products and related industries.
__________________________ appreciates the ability to express its views on this proposed rule. Should you have any comments or questions I will be happy to speak to you.