From: Pafiwdc@aol.com
Sent: Thursday, November 21, 2002 1:51 PM
To: rule-comments@sec.gov
Subject: SEC Proposal on Mutual Fund Proxy Voting Disclosure
November 21, 2002


Mr. Johnathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

Re: File #S7-36-02

Dear Mr. Katz:

On behalf of the 7,000 (members/beneficiaries) of the Iron Workers District 
Council Philadephia and Vicinity Pension Plan(union/pension fund), I am 
writing to express strong support for the Securities and Exchange Commission's 
recent proposal, S7-36-02, Disclosure of Proxy Voting Policies and Proxy 
Voting Records by Registered Management Investment Companies.  Most importantly, 
I strongly support those provisions that would require mutual funds to 
disclose their actual votes cast.

Our (beneficiaries/members) invest both individually, often through mutual 
funds, and through a variety of benefit plans, including 401(k) plans that 
offer mutual fund investment options.  Like other investment managers our (members'/beneficiaries') pension assets, mutual funds face conflict of 
interest in voting proxies that could lead them to vote with management even 
if such votes are not in the best interest of our (members/beneficiaries).  
But unlike our other investment managers-which are required under ERISA to 
tell us how they vote-mutual funds have until now shielded their proxy voting 
from investors and regulatory scrunity.

I commend the Commission for proposing a rule that will end this double 
standard-a double standard that has allowed mutual funds to turn a blind eye 
to the kinds of corporate governance failures that have cost our 
(members/beneficiaries) dearly at Enron, Tyco and WorldCom among others.  
Mutual funds own roughly 20 percent of U.S. corporate equity, so their 
proxy-voting power can be instrumental in protecting our (beneficiaries'/members') 
retirement savings from the consequences of weak corporate governance.  The 
Commission's proposed rule would give investors the information they need to 
ensure that their mutual funds take this fiduciary responsibility seriously.

I thank you for the opportunity to comment on this proposal of behalf of the 
Iron Workers District Council Philadelphia amd Vicinity Pension Plan.

Sincerely,

E. W. Nick Craggs
Plan Manager