SEC Proposed Rule:
Disclosure of Proxy Voting Policies and Proxy Voting Records by Registered Management Investment Companies
Proxy Voting by Investment Advisers
[Release Nos. 33-8131, 34-46518, IC-25739; File No. S7-36-02] File No. S7-36-02]
[Release No. IA-2059; File No. S7-38-02]
The following information using Type Letter H, or variation thereof, was submitted by
Subject: Proxy Voting
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:
As an individual investor, I am
writing to support 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. With almost all my
investments managed by mutual funds, I would greatly benefit from having the
information of how the institutions managing my money are voting proxies on my
behalf. This information would enable me to choose a mutual fund manager that is
voting proxies in line with my values on a range of issues of importance to me,
from corporate governance to social and environmental issues.
individual investors, I urge the SEC to require that disclosure of proxy votes
and voting guidelines be directly disclosed on mutual fund and investment
advisers' web sites, in addition to the SEC's web site. I believe print copies
should be made available to those investors that do not have access to the web,
or for small companies covered by the rule that do not have a website.
Additionally, I would like to see more specific guidance from the SEC on what
should be covered in a proxy voting policy or set of guidelines. Hundreds of
resolutions are filed by shareholders each year, on a range of issues, and
voting policies should be broad enough to reflect the diversity of concerns
coming to a vote.
I am concerned about current potential conflicts of
interest that may influence my money managers to vote proxies in ways that do
not reflect the interests of individual shareholders. I believe full disclosure
of proxy voting (which some socially responsible investment funds already do) is
an easy but critical step in protecting the interests of individual shareholders
and addressing some of the corporate scandals of the past year.
for the opportunity to comment on the proposed rules.