Date: 1/13/98 9:46 AM RE: File No. S7-25-97 Dear Members of the Securities and Exchange Commission: I am writing to protest the proposed changes in the rules governing shareholder resolutions now before the Securities and Exchange Commission. On the basis of what I have heard and read, the net effect of the changes currently under consideration would be to disenfranchise shareholders, favor corporations, and discourage shareholder advocacy. The Committee on Mission Responsibility Through Investments of the three million member Presbyterian Church (USA) has the responsibility of advising the Board of Pensions and Presbyterian Foundation concerning their investment of over $5.4 billion dollars. This committee, working closely with the Interfaith Center on Corporate Responsibility, takes quite seriously its assignment to initiate shareholder resolutions and support other faith communitiesO resolutions which reflect the stands on economic and social justice issues taken by the denominationOs annual General Assembly. By making it harder to resubmit shareholder resolutions and allowing management to exclude resolutions on issues that are new or difficult to quantify, the proposed rules would have a profound impact on the future of corporate social responsibility and socially responsible investing. I urge you to respond positively to the objections of the coalition of religious investors, state and municipal pension funds, organized labor, socially responsible investor organizations and managements firms, foundations and consumer, environmental and civil rights groups, and to seek a revision of the proposed changes in order to preserve the historic process of filing shareholder resolutions to insure corporate responsibility. Sincerely Harry E. Smith, Chair Committee on Mission Responsibility Through Investments Presbyterian Church (USA)