December 19, 2005
Dear Sir,
In response to the proposed rule re: proxy materials and annual report
mailing no longer being required I have some thoughts for you to
consider before you make your final decision.
In your email/press release you say that 75 of shareholders are on line
and therefore able to receive electronic delivery. What happens to the
other 25? What about the 75 of seniors who do not have on line access
but are active investors? 65 of active on line users give or take, are
still on 56K modems and downloading material of this nature is difficult
at best under that circumstance. By approving this initiative you give
rise to an even bigger claim that the markets are in the hands of the
professionals at the expense of the little guy and individual investor.
Communicating with shareholders can be viewed as an enormous expense or
as an enormous opportunity. In excess of 50 of listed NASDAQ companies
have one or no analyst covering them and I believe for the NYSE the
number is closer to 33. That is a significant number of companies who
under this rule will have no obligation to tell the shareholder base
what they are doing with their money unless shareholders can find an
internet connection. You also refer in this proposal to the fact that 10
million people have elected to receive their materials on line. You
neglect to include the fact that nearly 2 million of those have since
requested to return to paper delivery. Also not mentioned is the fact
that literally hundreds of millions of opportunities to select the on
line delivery option have gone out and the percentage of those who say
yes is miniscule in comparison.
There are other reasons to refuse to pass this proposal. What one puts
out on the web is not necessarily what everyone will see. Your operating
system and browser can change substantially the way material is viewed.
For example anyone on a MAC using the operating system OS9 and
Microsofts IE browser will see virtually nothing of what is on
line. Just look on different browsers at the same page of your favorite
web site and see the difference.
I could add all the places one reads to the argument and its not at a
computer and the impact this initiative would have on the paper, print,
design and mailing house communities as well as its impact on the
USPS but I sense youve heard that from many others. From the
shareholder perspective however, this initiative is exclusionary and in
this era of transparency flies in the face of what should be required.
We need more communication not less.
Thank you
--
scott l. greenberg, president
curran connors, inc.
333 marcus boulevard
hauppauge, ny 11788-2033
t. 631.435.0400 f. 631.435.1604
www.curran-connors.com