From: Ilene Davis [ilenedavis@megabits.net]
Sent: Tuesday, February 18, 2003 12:51 PM
To: rule-comments@sec.gov
Subject: MUTUAL FUND PROXY DISCLOSURE (s7-51-02)

I am writing as both a stockbroker, certified financial planner, and investor 
encouraging you to ignore requests from the industry to delay implementing the 
rule requiring disclosure of proxy votes.

First, it shouldn’t be either that hard or expensive to implement.   All that 
needs be done is to keep a LOG showing the name of the company, the issue, and 
how they voted ON BEHALF OF SHAREHOLDERS.

It appears mutual fund management, and their lobby, is forgetting whose money 
they are managing.  It is not THEIR money, it belongs to and finances the future 
of the people who paid for those shares, and pay for honest, transparent 
management.

And it seems to me that if a company can’t keep a SIMPLE LOG summarizing actions 
they took as fiduciaries on behalf of those they have a moral and legal obligation 
to act as fiduciary for, they should not be allowed to manage other people’s money.

While it is true they may lose investors who disagree with their votes,  secrecy 
is not the answer.   Investors who disagree with how their manager votes should 
have the information available to decide whom he/she wants to manage his/her monies.      

PLEASE DO NOT CAVE IN.    THE TRUST OF INVESTORS HAS BEEN SEVERELY ERODED.  IF THE 
SEC BACKS DOWN ON THIS, I’M NOT SURE I COULD LOOK A CLIENT IN THE EYE AND TELL HIM 
ITS SAFE TO INVEST IN ANYTHING OVERSEEN BY THE FEDERAL GOVERNMENT.    



Ilene Davis
315 Brevard Ave #3 Cocoa FL  32922
321/631-1127