From: Richard Mehl [scholar13@prodigy.net]
Sent: Tuesday, December 03, 2002 7:16 PM
To: rule-comments@sec.gov
Subject: Comment on File No. S7-36-02 

Dear sirs:

    I wish to comment on the proposed rule requiring mutual funds to
disclose their proxy voting policies and records ( File No. S7-36-02 ).
    I think it is entirely reasonable to require such disclose to be
available to shareholders on request and also to be posted on the Fund
Company's Webpage. This will raise costs a bit, but will not be so
burdensome as requiring such information to be printed in annual reports and
distributed to all shareholders.
Annual or semi-annual disclosure seems sufficient to me.
    Shareholders can compare how their mutual fund managers are voting on
important matters of corporate governance with votes recommended by
independent advisors and organizations concerned with corporate
accountability.
Shareholders can question and put pressure upon Fund Companies to adopt
better policies.  In the light of recent business scandals and bloated
salaries and benefits for corporate officers, improved oversight is needed.
    Individula investors can scarcely keep up with rapid changes on the
corporate scene.  Mutual fund managers and their support staff of analysts
are the logical group to police publicly owned businesses.  They hold huge
blocks of stock in many companies and can exert great influence on corporate
financial, environmental, and ethical practice.

Sincerely ,    Richard C. Mehl,  Kalamazoo, Michigan