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December 2, 2002 Jonathan G. Katz, Secretary
Dear Mr. Katz, My name is Donald T. Berry. I am writing to you in reference to File No. S7-36-02. I am currently a trustee for the IBEW Locals 570 and 518/Saguaro Chapter NECA Pension Plan and am also a private investor in a former 401K, which was rolled over into an IRA account with Vanguard. I agree the SEC should adopt its proposed rule requiring mutual funds companies to disclose their proxy votes to fund investors. The Labor Department requires pension fund managers that oversee investment of union pension plans to disclose their proxy votes. There should be no difference in disclosure rules for the two types of funds. I feel that as an investor in mutual funds, I should have access to the proxy voting records of the CEOs of the mutual fund companies or their money managers. This will, I believe, help to remind them who they really should represent in the investment of the money. If the proxy voting does not benefit my union's pension funds or my personal IRA funds, then I want to be able to give that fiduciary responsibility to someone who will vote their proxy in favor of my interests and investments....not some corporate executive using his company's coffers for his benefit. If the Mutual Funds Investment Industry is doing more than 50% of 401K retirement plans, this will allow small investors like me to know that these individuals are truly acting in the best interest of the investors - not the company executives. This will most likely help prevent another ENRON! Being allowed to get the proxy voting record information I need, whether acting as an individual or as a trustee on a pension plan, would ensure that the involved mutual fund companies exercise independent judgment in their proxy voting rather than let corporate client relationships influence their proxy votes in support of runaway executive pay, conflicted auditors, and entrenched boards of directors. It's time for the mutual fund companies to be held accountable, without exception!
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