From: 	Bob Rutkowski [mailto:rutkowski@terraworld.net] 
Sent:	Wednesday, November 13, 2002 9:25 AM
To:	chairmanoffice@sec.gov
Cc:	Tom Daschle; Trent Lott; Dennis Hastert; Nancy Pelosi; George W. Bush; 
Lawson, Rochelle B.
Subject:	Mutual-Fund Disclosure

Acting Chairman
Secretary Jonathan Katz
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
chairmanoffice@sec.gov

Dear Chairman and Secretary Katz

As you probably know, the Securities and Exchange Commission (SEC) is currently 
seeking comment on a proposed rule (published Sept. 19) that would require mutual 
fund companies to publicly disclose documents related to proxy voting, in which 
the company votes as a shareholder on behalf of mutual fund owners.

I support the proposed rule changes, requiring disclosure of both proxy voting 
guidelines and actual voting records.

Proxy voting disclosure will help ensure that fund managers are supporting corporate 
governance practices that are consistent with the best interests of their shareholders, 
and help to eliminate the perception that fund managers may use their proxies to 
vote in their own business interests instead. It will aid in the continuing effort 
to make corporate management properly accountable to investors. With disclosure, 
for example, investors will know how votes are cast on key issues (i.e., executive 
compensation, stock options, etc.) that directly affect their interests. In addition, 
disclosure could also encourage mutual funds to become more attentive to the 
corporate governance of the companies in their portfolios.

If the proposed rule is adopted, mutual fund companies will be required to:

*disclose the policies and procedures they use to determine how to vote proxies 
of companies in their portfolios;

*disclose procedures the fund uses when a vote presents a conflict of interest for 
the fund's investment adviser;

* disclose its complete proxy voting record in filings with the SEC;

*disclose in the annual and semi-annual reports to shareholders any proxy
votes that are inconsistent with the fund's policies and procedures, along
with an explanation for the inconsistency; and

* provide information about its proxy voting policies and procedures and 
voting record to shareholders upon request.

Thank you for the opportunity to bring these remarks to your attention.
Mindful of the responsibilities which stand before you, I am,

Yours sincerely,

Robert E. Rutkowski

cc:
	Rochelle B. Lawson
	Investor Assistance Specialist
lawsonrb@sec.gov

Andrew H. Card, Jr.
Speaker Dennis Hastert
Representative Nancy Pelosi
Senator Tom Daschle
Senator Trent Lott

2527 Faxon Court
Topeka, Kansas 66605-2086
P/F: 1 785 379-9671
r_e_rutkowski@hotmail.com