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On Shareholder Proposals: Update

After hearing from a few people, let me clarify:

1. The purpose of the SEC may be to protect investors, but on April 28, 2003, every major US investment bank was found to have aided and abetted efforts to defraud investors. Ethical problems have continued and grown worse: since late 2006, 182 major U.S. lending operations have "imploded" due to subprime lending issues. Most people losing their homes are low to moderate income people of color. This is no accident. Those with new ideas and solutions to the problem have been carefully excluded from the discussion, due to the same bigotry that gave rise to it. This, too, is no accident. We do not mean to sound cynical. We see what is, not what we would like to see.

2. The real issue is Hedge Funds, nothing else. In our comments to the SEC on the matter, we noted: "Any significant concern about proxy access rests with hedge funds, by their nature neither long term investors or sensitive to broader social concerns. The strategy of using proxy access to enhance shareholder value has been co-opted by certain hedge funds, now using the practice for selfish, potentially destructive purposes." As above, those with new ideas and solutions to the problem have been carefully excluded from the discussion. Again, this is no accident.

3. Restricting proxy access until something can be done about hedge funds may not be a bad thing, as long as full access is returned to small shareholders at some point.

4. All other concerns (special interest directors, electronic forums, state's rights, 5% ownership thresholds, etc.) are, for the most part, irrelevant.

The problem is the iceberg, not the lifeboats.

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