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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 J, or variation thereof, was submitted by 4 individuals.

Subject: Proxy Voting Policies and Records

Form Type Letter J:

I am writing in support of the SEC's proposed rule (File No. S7-36-02) to require mutual fund companies to disclose how they vote on corporate proxy resolutions, which often deal with issues of concern to me. I want to know how my mutual fund is voting on issues related to:

    Executive compensation programs,
    Board make-up and independence,
    Environmental issues,
    Worker rights,
    Auditor Selection,
    Gender discrimination, and
    Other important issues that matter to me.

The recent wave of corporate scandals provides ample evidence that corporate America need greater transparency, responsibility and accountability. It is estimated that mutual funds, which represent about 90 million Americans, account for 20 percent of proxy votes at corporate shareholder meetings. As such, mutual funds can play a major role in insisting on more responsible behavior on the part of publicly traded companies.

In the absence of public disclosure of proxy policies and proxy voting records, there is no way for me to know/verify whether the manager of my mutual fund is acting in a manner that reflects my best interests as an investor. As a mutual fund shareholder, I want potential conflicts of interest exposed. I want to know what principles will guide the mutual fund in determining how it votes in corporate proxy contests.

I believe that as an owner of mutual funds, that I am entitled to know how my proxy is being voted. I urge the SEC to stand up for investors and for corporate accountability and to vote in favor of the proposed proxy voting rule.

I cannot emphasize enough how deeply this issue affects me in my investment decisions. My confidence in the markets has been so shaken that I have not made any further investments in specific equities and I am critical now of how my mutual funds are being managed and used to intentionally or unintentionally continue to promote such future scandals.

Despite the argument by the Mutual Fund industry that disclosure will place an undue burden upon their businesses due to the shear number of votes they would need to document and report, it does not supercede the investors 'right' to this information and its influence on an investor's ability to make clear and fully-informed investment decisions. The SEC should require each mutual fund firm to product 'Electronic disclosures' of this information; not unlike the SEC's "Edgar" database for corporate filing disclosures.



Modified: 01/30/2003