October 16, 2002

Mr. Jonathan G. Katz
Secretary, Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609

Dear Mr. Katz:

I represent the Board of Trustees of the Iron Workers Pension Plan and Profit Sharing Plan of Western Pennsylvania. It is my understanding that the SEC is now considering adopting a rule requiring mutual funds to disclose their proxy votes to fund investors.

These pension funds have considerable assets invested in mutual funds. We would strongly recommend that you adopt the proposed rule requiring mutual funds to disclose their proxy votes.

This disclosure would prevent possible conflicts of interest that would influence a mutual fund company's voting in favor of management proposals that could be contrary to the best interests of the fund investors.

Your consideration will be appreciated.


Boe W. Gillespie, CEBS
Administrative Manager


CC: Hank Foley