January 18, 2000
Jonathan G. Katz
Secretary, Securities and Exchange Commission
450 5th Street, N.W.
Washington, D.C. 20549-0609
Reference: File No. S7-26-99
Delivery of Proxy and Information Statements to Households
Dear Mr. Katz:
In response to the Securities and Exchange Commission's request for comments concerning the proposed rule for Delivery of Proxy and Information Statements to Households, ChaseMellon Shareholder Services, L.L.C. ("ChaseMellon") is pleased to submit the following. ChaseMellon is one of the largest providers of shareholder services in the United States.
Section II.B.2., Addressing
ChaseMellon recommends that the rule permit addressing the householding envelope to one of the consenting shareholders rather than creating a new household mailing label, e.g., Jane Doe and Household or Household of Jane Doe. Under current industry practice, shareholders are addressed by having the proxy card name and address appear through a window envelope. Requiring that a separate household label be produced increases the complexity and cost to issuers of householding, and may result in fewer issuers adopting its benefits.
Section II.C., Householding of Proxy and Information Statements by Intermediaries to Beneficial Owners
ChaseMellon recommends that, if a registered shareholder gives householding consent, that consent be automatically extended to the holder's beneficial positions held by the issuer's transfer agent, e.g., shares in a 401(k) or an employee stock purchase plan, that are consolidated with the shareholder's file. Under current operating procedures, when a registered shareholder's position is matched with his or her employee plan positions, one proxy card is created. Allowing the consent to household for a registered position to apply to these beneficial positions would be cost effective and be consistent with the intent of the rule.
ChaseMellon appreciates the opportunity to comment on the proposed rule and supports the Commission's efforts to facilitate the distribution of materials to shareholders.
Very truly yours,
/S/ Gerald Popovsky
Vice President and Associate Counsel