Our support for Amendment 1 is conditional. For the reasons stated below, we believe the Commission should focus on the question of whether the level of service and reliability in the proxy process will be diminished by reducing the fees as Amendment 1 proposes. The Association and its Board members have participated in the effort to improve the proxy delivery system for more than three years. Each NYSE submission has been the result of extensive negotiations involving representatives of all the most interested parties to the proxy fee reimbursement transaction. Through these negotiations, two clear priorities have emerged for all issuers.
Issuers value reliability of delivery and vote tabulation.
They also value the opportunity to reduce total cost. On the other hand, cutting intermediary fees further is not a high priority. The February Proposal fee structure provided the assurance of the current high level of reliable service. With the exception of a five-cent reduction in the unit fee, it was the same fee structure under which substantial improvement in the reliability, and significant reduction in issuers' total costs were realized during the 1998 and 1999 proxy seasons. A strong consensus among issuers supported this proposal.