From: Gamble, Bruce (DCRB) [Bruce.Gamble@dc.gov] Sent: Friday, June 13, 2003 2:32 PM To: 'rulecomments@sec.gov' Subject: File No. S7-10-03 To: Mr. Jonathan G. Katz Secretary, Securities and Exchange Commission From: District of Columbia Retirement Board Date: June 13, 2003 Subject: S7-10-03 The District of Columbia Retirement Board ("DCRB") is an independent agency of the District of Columbia government ("District") that manages and controls the assets of the retirement funds for teachers, police officers and firefighters employed by the District. As a public pension fund representing the interest of over 13,000 participants and beneficiaries, DCRB believes that changes in the proxy rules which improve shareholder access to corporate proxy cards for nominating director candidates of public companies will help encourage increased accountability to shareholders, and serve to restore investor confidence. DCRB is writing the Commission in strong support of efforts to formulate changes to proxy rules and regulations designed to give investors a meaningful opportunity to participate in the process of nominating candidates for election to board directorships of publicly held corporations. Such rule changes should however protect corporations from abusive tactics during takeover attempts, and avoid unnecessary expense or burden on corporate management. Proxy rule changes that allow shareholders fair and equal access to company proxy cards to nominate directors will encourage greater dialogue between corporate management and shareholders, ultimately resulting in a better alignment of interests. Respectfully submitted, Mary A. Collins Chairman of the Board District of Columbia Retirement Board 1400 L Street, N.W., Suite 300 Washington, D.C. 20005