From: Leslie [lmoody@denverlabor.org]
Sent: Monday, November 25, 2002 4:13 PM
To: rule-comments@sec.gov
Subject: File No. S7-36-02

November 25, 2002

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

Re:  File No. S7-36-02

Dear Mr. Katz:

On behalf of the 80,000 thousand members of the Denver Area Labor Federation, 
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 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 that manage these pension 
assets, mutual funds face conflicts 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.  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 investor and regulatory scrutiny.   

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 thousands of 
employees 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 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 on behalf of 
thousands of Denver families.

Sincerely,

Leslie Moody, President
Denver Area Labor Federation, AFL-CIO
10 Lakeside Lane, Suite 1B
Denver, CO  80212
303-477-6111