Direct Tel. 020 7216 7670 E-mail Peter.Montagnon@abi.org.uk Direct Fax. 020 7696 8979
Jonathan G Katz Secretary US Securities and Exchange Commission 450 Fifth Street, NW Washington, DC 20549-0609	19 December 2003 Ref PMON/vs

Dear Mr Katz

PROPOSED RULE:SECURITY HOLDER DIRECTOR NOMINATIONS

I am writing with reference to the attached letter which has been sent to you by one of our members, Morley Fund Management. This letter has been considered by the Investment Committee of our Association which groups institutional investors controlling funds worth some $1,700bn. The Committee has instructed me to tell you that it fully supports the views expressed by Morley in its letter.

Morley's views are thus endorsed by a broad swathe of UK institutional investors with extensive holdings in US equities. We should be grateful if you would take this into account when considering responses to your current consultation.

Peter Montagnon
Head of Investment Affairs

Enclosure

cc: Iain Richards - Morley

[LV319121AINV/PMON/LETTERS/December 03]