From: Fred Kachuk [fredk@verizon.net]
Sent: Thursday, December 05, 2002 8:43 PM
To: SEC
Subject: S7-38-02

S7-38-02 
I am in favor of the proposed rule change which would require that 
investment advisors reveal their corporate proxy votes to the public.  

Advisers have denied this information to clients, and I believe a 
rule should be included that gives investors a right to this 
information. A good starting point for retention of the data would 
be 2 years so that it would overlap the annual proxy activity period.  

I also would prefer a rule which would prescribe the content and 
format of the vote tabulations, something very simple such as proxy 
item number and how many yes/no votes were submitted by the advisor. 

As far as the burden of implementing these rules, I believe that the 
proposal is a good starting point.  Who can measure the personal 
investments lost, jobs lost due to corporate malfeasance during the 
last few years?  Perhaps a more open picture of proxy voting might 
have prevented some of these immoral and criminal behaviors.

I personally review each proxy that is delivered to me as an individual 
and I am frustrated at what is happening with many proxy proposals, 
particularly those concerning executive compensation.

I believe that many of the mutual funds and other institutional holder 
of public stock are guilty of  "rubber stamping" many of these proxy 
proposals.

Another possible suggestion for implementing new rules would be to place 
the burden of reporting on the corporation instead of the investment 
advisors.

Although some may claim that these rules are burdensome, I believe that 
they are necessary and the technology exists to implement these new 
systems and procedures. It may also be wise to start looking at the next 
evolution of this process: allowing individual mutual fund shareholders 
the option to vote their portion of the proxies.