From: Kirsten Spalding [kspalding@calaborfed.org]
Sent: Wednesday, December 04, 2002 10:00 PM
To: rule-comments@sec.gov
Cc: Michael Garland; Martha Bader
Subject: File No. S7-36-02

December 4, 2002

Johnathan G. Katz, Secretary, SEcuirties and Exchange Commission
450 Fifth Street, NW
Washington, DC  20549

Dear Mr. Katz:

I am writing on behalf of the California Labor Federation, AFL-CIO and our
twelve hundred (1200) affiliated unions to support your proposed rule
requiring mutual funds to disclose thier proxy votes.

Proxy votes are a key responsibility of investment managers.  Under ERISA,
pension fund fiduciaries have a duty to vote proxies.  Pension beneficiaries
must hold their investment managers, consultants and trustees accountable,
by knowing how their proxies are cast. So should mutual fund managers be
accountable to individual and institutional investors.

Thank you for undertaking this important rule making, please convey our
strong support to the Commission.

Yours sincerely,


Kirsten Snow Spalding
Chief of Staff
California Labor Federation, AFL-CIO
600 Grand Avenue, Suite 410
Oakland, CA  94610-3561

ph:  510-663-4040
fax:  510-663-4099