November 5, 2002
Jonathan G. Katz, Secretary
Re: File No. S7-36-02
Dear Mr. Katz:
Please be advised that I, and my fellow trustees on the board of International Union of Operating Engineers Local 487 Fringe Benefit Trust Funds, strongly support proposed rules which would require mutual funds to disclose their proxy votes. It is our opinion that enactment of the proposed rule would help investors ensure that Fidelity Investments and other mutual fund companies don't allow corporate client relationships to influence their proxy votes in support of runaway executive pay, conflicted auditors, and entrenched boards of directors.
As you may be aware, Taft Hartley investment managers are already required by ERISA to disclose their proxy votes to their clients. The proposed rule would eliminate the double standard which has allowed mutual funds to hide their votes.
Again, we strongly support the proposed rule, and most importantly its provision that mutual funds disclose their actual proxy votes cast.