Subject: Please:  Stop Regulations S7-25-97

Date:    11/18/97 12:31 AM
     
     
Dear SEC:
     
   I am writing because I am concerned about the effect of your proposed 
regulations (S7-25-97) on the small investor. These new rules seem 
effectively to take away the small shareholder's rights to have
our voices heard and our votes counted through corporate shareholder
ballots and at annual shareholder meetings.
     
   The regulations do nothing for the small investor and everything
for big business. Take the "over-ride" clause, for example. 3% of a
company's shares are needed to allow a ballot resolution despite management's
objections. For most Fortune 500 companies, 3% means more than $1 billion worth
of stock!  Please consider keeping the over-ride idea but only with a $10
million dollar cap. This is a reasonable manner to ensure access to the
shareholder ballot for average shareholders-it will give small shareholders
a reasonable goal to reach in combining their voices, not an impossible one
as with the 3% proposal.
     
   Increasing the percentage needed to reintroduce an issue is
another example of how the new regulations favor corporate management at the
expense of regular Americans. Please let the existing resubmission
thresholds stand.
     
   Don't take away small investor's tools for protecting their financial 
interests in a company. Reconsider your regulations.
     
   Secondly, your proposed regulations (S7-25-97) will pose a major
setback in the efforts to protect women and children's rights both in the
workplace and in the media.
     
   The shareholder resolution process is an absolutely
indispensable tool for concerned investors to engage in a dialogue with company
management about social issues, workplace practices and corporate accountability.
The new regulations would eliminate shareholders' ability to make their
voices heard.
     
   The shareholder advocacy campaign against tobacco sales to
children is an example of the power of the shareholder resolution process to bring 
important issues to the attention of management and make sure
action is taken.
     
   American consumers are becoming increasingly enraged about sweat
shops. Shareholder resolutions have played a crucial role in helping
stop sweat shops, which most frequently rely on exploiting children and
women both at home and abroad. The shareholder resolution process is already
helping protect companies from reputational backlash.
     
   Had Nike heeded the advice of concerned shareholders in past
years they would not be the regular target of America's most popular
cartoonist. Had they worked with shareholders they would not be struggling to
rebuild their extremely damaged public image. Shareholder resolutions protect the 
financial interests of shareholders.
     
   Please protect the rights of American shareholders to address
corporate behavior. Stop these regulations from going through.
     
           Sincerely,
     
           Joanie Misrack
     
     
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 
"It is man's vision of a world fit for rational, civilized humanity which 
leads him to dare to suffer to build societies free from want and fear.
Concepts such as truth, justice and compassion cannot be dismissed as trite 
when these are often the only bulwarks which stand against ruthless power." 
(Aung San Suu Kyi)
     
MAY PEACE PREVAIL ON EARTH, AND IN YOUR HEART....!
     
Joanie Misrack, Pathways To Peace