From: Steve Abrecht [ABRECHTS@seiu.org]
Sent: Monday, December 02, 2002 4:53 PM
To: rule-comments@sec.gov
Subject: Re: File No. S7-36-02

December 2, 2002  

Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW 
Washington, DC  20549 

Re:  File No. S7 36 02 

Dear Mr. Katz: 

On behalf of the 40,000 participants in the SEIU National Industry Pension Fund, 
I am writing to express strong support for the Securities and Exchange Commissions 
recent proposal, S7 36 02, Disclosure of Proxy Voting Policies and Proxy Voting 
Records by Registered Management Investment Companies.  I want to commend you 
in particular for those provisions that would require mutual funds to disclose 
their actual votes cast. 

Our participants have a lot a stake in today's financial markets.  Their retirement 
savings and security depend on the integrity, efficiency and transparency of the 
financial markets.  For many years our own fund has been held to the important 
standard of exercising its votes as a plan asset and in the best interests of 
participants.   

However our participants often invest additional savings through mutual funds and 
through 401(k) plans that offer mutual fund investment options.  Like other 
investment managers that manage our participants pension assets, mutual funds face 
conflicts of interest in voting proxies that could lead them to vote with management 
even if such votes are not in the best interest of investors. But unlike our other 
investment managers which are required under ERISA to tell us how they vote, mutual 
funds have until now shielded their proxy voting from investor and regulatory scrutiny.   

I commend the Commission for proposing a rule that will restore investor confidence 
in financial markets by ensuring that all decisions taken by mutual funds, including 
their proxy voting, are grounded in the interests of investors and are not contributing 
to further corporate governance failures.  

Mutual funds own roughly 20 percent of U.S. corporate equity, so their proxy voting 
power can be instrumental in protecting our participants' retirement savings from 
the consequences of weak corporate governance.  The Commission's proposed rule would 
give investors the information they need to ensure that their mutual funds take this 
fiduciary responsibility seriously.   

I thank you for the opportunity to comment on this proposal on behalf of the SEIU 
National Industry Pension Fund.  

Sincerely, 

Steve Abrecht
Executive Director