From: Karin Uhlich [karin@economicintegrity.org]
Sent: Wednesday, December 04, 2002 11:46 PM
To: rule-comments@sec.gov
Subject: FILE NUMBERS S7-36-02 and S7-38-02

Re: File Numbers S7-36-02 and S7-38-02


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

Dear Secretary Katz:

I am writing on behalf of the Southwest Center for Economic Integrity 
(SCEI) in support of the Security and Exchange Commission's recently 
proposed rules regarding proxy voting guidelines and vote disclosure by 
mutual funds and investment advisers, File Numbers S7-36-02 and S7-38-02. 
The mission of SCEI is to build economic strength by advancing fairness, 
understanding, and community action.  We congratulate the Security and 
Exchange Commission for instituting meaningful disclosure that we believe 
will in fact bolster fairness, understanding and appropriate action on the 
part of investors.  We strongly support the recommendations set forth in 
these proposed rules.

Many of the points we would seek to advocate have been powerfully stated 
already by the Social Investment Forum.  We urge you to take their 
recommendations into account as you move toward implementation.  

The informed involvement of shareholders, whether directly or through mutual 
funds or advisers, will be critical in the effort to ensure greater corporate 
accountability and a more sound market system.  Without true transparency and 
engaged proxy voting we cannot hope to achieve those ends.

Thank you for the opportunity to share our views on these important proposed 
rules.

Sincerely,

Karin Uhlich, Director
Southwest Center for 
    Economic Integrity
509 S. Sixth Avenue
P.O. Box 41972
Tucson, AZ   85717-1972
Phone: 520 971-1472
Fax:       520 743-9110
karin@economicintegrity.org