Calvert Group, Ltd.
December 6, 2002
Mr. Jonathan G. Katz, Secretary
Dear Mr. Katz,
Although I serve in a professional capacity as the President and CEO of Calvert Group, Ltd., a financial services firm that serves as investment advisor, administrator and distributor for a family of mutual funds though it's various corporate entities. I am writing this comment letter as a personal expression of my support for the proposed rule requiring disclosure of Proxy Voting Policies and Proxy Voting Records.
There are many reasons why mutual funds are ideal savings and investing vehicles for Americans. As you know, tens of millions of Americans have entrusted mutual funds with their savings and investment dollars in order to meet a range of individual and family goals, particularly in the areas of retirement and college savings. In brief, professional management, low minimums (that encourage all Americans to invest and save), simple and clear disclosure documents, and transparency, are just four of these reasons. I feel the proposed rule is fully in the spirit of working to maintain the public's trust, and should be finalized as proposed.
Calvert's letter well addresses many of the objections that have been raised by those few, surprisingly large, mutual fund complexes who have objected to the proposed rule. The cost objection is particularly confusing, since these firms spend millions on their websites, and on marketing and advertising every year. The de minimis cost of adding proxy voting policies and votes, on request, even if the Fund family had to absorb the cost, is not sufficient to outweigh the positives.
The two objections I would like to specifically comment on are the "softer" issues of "shareholders aren't requesting this disclosure" and "disclosing votes will politicize the process." Upon analysis, neither of these objections makes sense to me.
First, to the matter of gauging shareholder requests as the driver of disclosure policies, I suspect that if we used that "test" on many of the disclosures written into the original securities acts, we wouldn't have much disclosure at all! It is simply an inappropriate "test" to apply to setting policy. In general, I believe investors trust that regulators, and investment managers, are working on their behalf to assure that they will have available to them sufficient information to judge all aspects of investment policy and investment advice, including the voting policies, and votes cast by their investment manager at annual shareholder meetings. That is why Calvert, among others, has voluntarily chosen to provide proxy voting guidelines and actual voting records as described in this rule.
Second, to the matter of politicizing the proxy voting process, I fail to see how adding this disclosure changes any aspect of the current system, other than to make it more fair and democratic. Investment managers should have the intellect and will to establish policy, and act on it, in a fully disclosed manner. Shareholder input should be welcomed. If that shareholder input turns to pressure, the investment manager should have the courage of his or her convictions. Hiding the proxy policies and votes from the plain view of shareholders is simply the wrong answer.
Again, I would like to commend the Commission for the proposed rule, and encourage its adoption.