From: Ralph Wanger [rwanger@wanger.com]
Sent: Thursday, October 24, 2002 5:13 PM
To: 'rule-comments@sec.gov'
Subject: file 57-36-02

	The goal of the proposed rule on Fund proxy voting is virtuous, but
mandating public disclosure of proxy votes may have unintended consequences.
There may be some times that we want our votes publicized, but other times
we don't, because quiet diplomacy sometimes works better in persuading
companies to do the right thing than does public controversy.
	In economic terms, forced public disclosure of our actions puts a
higher "cost" on voting against management than we have now, and increasing
the cost of an action causes less of it. To get more activist votes from
mutual funds, make it cheaper, not more costly.
	At the Liberty Acorn funds, we have an active proxy committee, and
vote "no" on dozens of proxies every year. I sat next to Arthur Levitt at
lunch a few days ago and we agree that mutual funds have a major role in
enforcing better corporate governance. However, putting through new rules
just to look active may be counter-productive.