U.S. Securities & Exchange Commission
SEC Seal
Home | Previous Page
U.S. Securities and Exchange Commission

SEC Proposed Rule:
Disclosure of Proxy Voting Policies and Proxy Voting Records by Registered Management Investment Companies

[Release Nos. 33-8131, 34-46518, IC-25739; File No. S7-36-02] File No. S7-36-02]

The following information using Type Letter G, or variation thereof, was submitted by 3,279 individuals.

Subject: Proxy Voting Policies and Records

Form Type Letter G:

SEC Secretary (or Mr. Jonathan G. Katz)
450 Fifth Street, NW
Washington, DC 20549

Dear SEC Secretary (or Mr. Jonathan G. Katz),

I am writing to express my strong support for the SEC's proposed rule (S7-36-02) to require mutual funds to disclose their proxy voting policies and, most importantly, their actual proxy voting decisions.

I am tired of hearing representatives of the mutual fund industry say that fund investors don't care how their funds vote proxies. I am a mutual fund investor and I care. Moreover, I think it's improper for the mutual fund industry to pretend to speak for investors on the issue of proxy voting, since my interests as an investor may differ from those of my mutual fund company, which could maintain business relationships with portfolio companies.

Mutual fund companies have enormous power to shape corporate governance to better protect investors like me from the consequences of overpaid CEOs, entrenched boards of directors and conflicted auditors. Unfortunately, mutual fund companies also have a self-interest in voting with management to avoid disrupting their business relationships.

Fidelity Investments, the world's largest mutual fund company, is a good example. Although Fidelity generally refuses to disclose its proxy votes, it did disclose that it voted against a 1998 shareholder proposal calling for a majority of independent directors at Tyco International, a company that has paid Fidelity millions to administer its employee benefit plans.

Recently, nine Tyco board members voted not to re-nominate themselves for election as directors next year amid allegations of improper accounting practices and financial wrongdoing by several top former executives. I question whose interests Fidelity was promoting when it cast its 1998 proxy vote.

I expect my mutual fund company to cast its proxy votes--which effectively belong to me and other mutual fund shareholders--so as to protect and promote our interests regardless of the impact that such votes could have on its client relationships.

Requiring mutual funds to disclose their proxy votes in an easily accessible format is the only way that investors can ensure that Fidelity and other mutual fund companies exercise their proxy voting authority to promote our interests rather than to boost their own bottom line.

I strongly urge to SEC to adopt its proposed rule.



Modified: 12/08/2002