Subject: don't limit rights of small investors

Date:    11/17/97 3:41 PM
     
     
To the SEC:
     
As a small investor,  I am concerned about the effect of your proposed 
regulations (S7-25-97). These new rules effectively destroy the small 
shareholders' right to have our voices heard and our votes counted through 
corporate shareholder ballots and at annual shareholder meetings.
     
Every analysis I've read indicates that small shareholders were the ones who 
helped the stock market rebound so rapidly after the big sell-off this 
October. We're the ones holding stocks for the long term, and are proud of 
ownership in the companies whose stocks we own. Many of us do our own 
research, work with groups of other small shareholders to evaluate and 
invest in these companies, and rely on our ability to secure our investment 
by influencing the way the companies whose stock we  own do business. These 
are the practices upon which our stock market was founded; that is, an 
investor has a right to comment on the way her/his investment is being used.
     
The new regulations harm independent shareholders, and our right to protect 
our investments, while benefitting those in power in big business. For 
example, according to the new regulations, if management objects to a ballot 
resolution, 3% of a company's shares are needed to get the issue on the 
ballot.  For most Fortune 500 companies, 3% means more than $1 billion worth 
of stock. The override idea, itself, is a good one - just as we require a 
minimum number of signatures for an issue to find its way to the voters in a 
public election, we should require some indication of broad interest in 
shareholder resolutions. However, rather than creating a percentage minimum, 
create a dollar minimum that is more achievable for small investors pooling 
their voices.
     
Don't take away small investors' tools for protecting our financial 
interests in a company. Reconsider your regulations.
     
With hope,
     
Brie Gyncild
Seattle, Washington