From: Arsenault [farse@annapolis.net]
Sent: Monday, November 04, 2002 7:35 PM
Subject: S7-36-02

I strongly support a requirement that a management
investment company registered under the Investment Company
Act of 1940 ("fund") disclose in its registration statement
the policies and procedures that it uses to determine how to
vote proxies relating to portfolio securities.

I also support a requirement that a fund file with the
Commission the fund's proxy voting record and to disclose in
its annual and semi-annual reports to shareholders
information regarding any proxy votes that are inconsistent
with its proxy voting policies and procedures.

With regard to the proposed requirement that the fund make
available on request free of charge its proxy voting record,
I am concerned that the costs involved could be significant
and that they will adversely affect returns. If the proxy
voting record is made available on the web by both the fund
and the SEC, requests for paper copies should be charged a
nominal fee A reasonable fee would be appropriate and would
reduce the likelihood of frivolous requests.