November 14, 2002


Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street N.W.
Washington, DC 20549-0609

RE: File No. S7-36-02

Dear Mr. Katz:

The Ohio Public Employees Retirement System (OPERS) is writing in support of the SEC's proposed rule, File No. S7-36-02, requiring mutual fund companies to disclose their votes on corporate proxy resolutions. OPERS believes this is a critical and beneficial step toward promoting better corporate governance.

OPERS strongly supports the current recommendations set forth by the SEC requiring mutual funds to disclose general proxy voting policies and procedures, including the disclosures listed below:

OPERS also supports the following disclosure of specific types of issues:

OPERS believes disclosure of funds' proxy voting policies, procedures and voting records will benefit investors in a number of ways. Such disclosure will:

OPERS believes proxy voting is an important fiduciary duty of a fund's investment advisor and, therefore, should be disclosed. The recent wave of corporate scandals provides ample evidence that corporate America is in need of greater transparency, responsibility and accountability. The SEC proposed rules are overdue and will go a long way toward restoring investor confidence.



Laurie Fiori Hacking
Executive Director
The Ohio Public Employees Retirement System