Subject: File No. 265-28
From: James McRitchie
Affiliation: Corporate Governance (

November 7, 2014

Most people dont own stock but most who do own stock probably do so through mutual funds or collective investment trusts (CITs) in their employers deferred compensation plans. While the SEC requires mutual funds to disclose their proxy votes, there appears to be no such requirement for CITs or for deferred compensation plans as a whole. I cant even get my plan to disclose how any of the funds voted, even mutual funds. Any chance the SEC-IAC will address this issue?


It is like proxy requirements that are meant to protect investors but fail because most investors get voter information forms and never see a real proxy. What good are SEC disclosure rules if they only protect the large institutional investors with lots of expert staff, instead of more vulnerable retail investors?