From: Steve Steinberg [stevegs@earthlink.net]
Sent: Sunday, December 01, 2002 12:38 PM
To: rule-comments@sec.gov
Subject: File No. S7-36-02

Re: Disclosure of Proxy Voting Policies and Proxy Voting Records by Registered 
Management Investment Companies
 
I support this proposed rule.  Anything that brings more sunshine to bear on how 
our corporations are run has to be good.  We should keep in mind that the people 
who own shares in mutual funds are the true owners of corporations.  They are 
entitled to know how their property is being managed by asset managers.
 
I urge you to require asset managers to provide detailed information on each 
shareholder vote.  Please assure that asset managers have to provide this data 
in a timely manner, perhaps within three business days of the vote.  I believe 
it is acceptable for asset managers to provide this information only via the 
World Wide Web, provided that they provide the data both on their own Web site 
and via the SEC's Web site.  This is the type of detailed information that the 
Web handles well.  While many Americans still do not have good Internet acess, 
the number is growing, and those that do not can often make use of colleagues' 
access, facilities provided by their employer, or public access terminals at 
libraries.  The idea of this proposed rule is to give more information to investors 
and to push asset managers to be more acountable, not to increase costs for mutual 
fund holders.
 
My only objection to this proposed rule is that it does not go far enough.  I would 
like to see asset managers allow the owners of their shares to instruct the asset 
manager on how the asset manager is to vote on corporate matters.  Further, for 
cases where the asset manager owns a significant stake in a corporation, asset 
managers should solicit nominations for Board of Directors from the people who own 
shares in the mutual fund.  While asset managers will object to this loss of control, 
modern World Wide Web technology will make it feasible.  Still, the proposed rule is 
a good start.  My objection is not reason to oppose the rule.
 
Incidentally, asset managers should disclose to their owners what position, if any, 
they take on this proposal and how much money they spent doing so.
 
Steven Steinberg
232 East 12 Street #6A
New York, NY  10003