From: Hunter Lovins [hlovins@rmi.org]
Sent: Thursday, December 05, 2002 12:54 PM
To: rule-comments@sec.gov
Subject: Please require transparency from mutual funds

Dear SEC,

Please reform your rules to ensure that mutual fund proxy voting 
become transparent

Shareholders have a right to know how their mutual fund is voting. 
You have stated that proxy voting is a fiduciary duty of mutual 
funds. I agree. But you need to close the configuration. As a 
shareholder of a mutual fund, I have a right to know how my fund 
voted. Are the votes on my behalf encouraging better management? Are 
they encouraging greater diversity on boards of directors and more 
responsible environmental practices? Or are they rubberstamping 
Enron-like practices, unwise compensation packages or allowing 
companies to flee to tax havens?

When voting must be reported, shareholders can track funds and 
managers that are  encouraging better corporate accountability. When 
funds disclose their proxy voting policies, I will be able to judge 
whether they are acting in my best interests, or are whether they are 
just caving in to corporate pressure. Proxy voting transparency is 
critical to good mutual fund governance and is critical to protecting 
my interests.

I urge you to require such transparency.

Thank you for your consideration.

L. Hunter Lovins