Subject: S7-16-07

School Sisters of Notre Dame
345 Belden Hill Road
Wilton, CT 06897

September 27, 2007


I write in reference to S7 - 16 - 07.
As a representative of investors, the School Sisters of Notre Dame, I take seriously my position with our rights and our responsibility to be engaged and informed on companies with whom we are shareholders. We strongly oppose proposals at the Securities and Exchange Commission (SEC) to either eliminate the shareholder resolution process or make it more difficult to sponsor resolutions. We also oppose any step to make it more difficult for investors to help nominate directors.

Shareholder advocacy works to make American corporations stronger. There is a long history of positive reforms and policies resulting from shareholder resolutions with companies. The rising support votes for resolutions, across a range of environmental, social and governance topics, indicate that a broad spectrum of investors increasingly understand, and take seriously, shareholder resolutions as a means by which to stimulate changes in companies.


Ethel Howley, SSND
Ass't Director of Justice & Peace Office
School Sisters of Notre Dame, Atlantic Midwest Province