Subject: File No. S7-19-07
From: Jean L Frye, IBVM

August 8, 2007

As a faith-based institutional investor, I want to express my opposition to any attempt to weaken or cripple shareholders right to file non-binding advisory resolutions under Rule 14a-8.

For over three decades, shareholder proposals have provided large and small shareholders with a voice in the governance of corporations on which their financial futures depend. Doing away with these proposals would be a setback for shareholder democracy and corporate governance more generally.

Eliminating this right would remove an important tool of management accountability to shareholders. We strongly oppose any effort to curtail this important component of shareholder democracy. We are also aware that engaged investors across the country are prepared to publicly defend their ownership rights should those be threatened by proposed rulemaking. We hope that instead of issuing controversial proposals that are harmful to shareholder interests, the SEC will consider how to enhance the dialogue between corporations and their owners on matters of strategic importance.