Subject: File No. S7-14-10
From: Wendy K. Nunez
Affiliation: Chief Compliance Officer, Champlain Investment Partners, LLC

October 19, 2010

As a user of proxy advisor research, we believe it is important for all proxy advisory firms to be transparent in regards to the end markets in which they serve. Investment advisors seeking additional guidance on various proposals should be made well aware of their proxy advisor's consulting relationships with the issuer. When issuers seek advice and guidance on the same proposals that investment advisors are voting on, the proxy advisor should disclose their relationship with the issuer along with fees paid for their services in clear, concise language directly on their research reports. Generic disclosures of such conflicts of interest which state that the proxy advisory firm may have a consulting relationship with the issuer do not go far enough in disclosing the nature of the relationship.