From: Sheila Beckett [sheila.beckett@ers.state.tx.us] Sent: Monday, May 19, 2003 3:35 PM To: rule-comments@sec.gov Subject: Re: Release No. 34-47778, File no. S7-10-03 Jonathan G. Katz Secretary Securities and Exchange Commission 450 Fifth Street, NW Washington, DC 20549-0609 Re: Release No. 34-47778, File no. S7-10-03 Dear Mr. Katz: The Employees Retirement System of Texas is a $17 billion public pension fund. We are responding to the Notice of Solicitation of Public Views Regarding Possible Changes to the Proxy Rules. It is encouraging that the commission is reviewing the procedures for which shareholders elect directors. Proxy voting and specifically the election of directors is an important and vital aspect of investing. It is one way for shareholders to oversee their investments and enhance their returns. The proxy vote is extremely important for funds, like ours, that do not always have the choice to divest a holding due to poor corporate governance. With the failures of Enron, Worldcom, et al, it has become imperative that shareholders ensure directors are acting in their interest and that directors are held accountable for their actions. Without the proper mechanism to effectively oversee directors, our markets are inherently riskier and less efficient. The current rules and procedures put us at a disadvantage to carry out our fiduciary duty in overseeing our investments. Better access to proxies and more disclosure will help facilitate this responsibility. Thank you again for taking steps to ensure our markets continue to set the standard for global markets. Sincerely, Sheila Beckett Executive Director Employees Retirement System of Texas 512.867.7174