Sacramento County Employees' Retirement System

Executive Staff
John R. Descamp
    Chief Executive Officer
Jeffrey W. States
    Chief Investment Officer
Linda Seher
    Chief Benefits Officer
Kathryn T. Regalia
    Chief Operations Officer

June 12, 2003

Jonathan G. Katz VIA EMAIL: rule-comments@sec.gov
Secretary
U.S. Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C. 20549-0609

Dear Mr. Secretary:

I am the Chief Investment Officer for the Sacramento County Employees' Retirement System. SCERS is responsible for investing the pension plan assets for Sacramento County's public employees. We invest on behalf of over 16,000 active and deferred member and pay benefits to over 5,500 retirees and beneficiaries.

SCERS and its Board very strongly believe that equal access to corporate proxy materials is of significant importance for shareholders who wish to propose alternative candidates for board seats and have a meaningful voice in a company's governance. The current system, which requires shareholders to lead expensive, and often litigious, proxy contests is badly in need of reform. We urge you to consider amending the rules in order to improve shareholder access to management proxy cards.

On behalf of the SCERS Board, our members, and our retirees, I would like to thank you for giving this request serious consideration. If you have any questions, please reply to this Email.

Sincerely,

Jeffrey W. States
Chief Investment Officer
Sacramento County Employees' Retirement System