Company Name: Bank of America Corp.
Public Availability Date: December 28, 2006
Document Sections:
INQUIRY LETTER
INQUIRY LETTER
APPENDIX 1
INQUIRY LETTER
APPENDIX 2
INQUIRY LETTER
INQUIRY LETTER
INQUIRY LETTER
INQUIRY LETTER
INQUIRY LETTER
STAFF REPLY LETTER
[INQUIRY LETTER]
December 5, 2006
BY OVERNIGHT DELIVERY
Securities and Exchange Commission
Office of Chief Counsel
Division of Corporation Finance
100 F. Street, N.E.
Washington, DC 20549
Re: Stockholder Proposal Submitted by the SEIU Master Trust
Ladies and Gentlemen:
On November 8, 2006, Bank of America Corporation (the "Corporation") received a
proposal and supporting statement ("Proposal A") for inclusion in the proxy
materials for the Corporation's 2007 Annual Meeting of Stockholders (the "2007
Annual Meeting") from a stockholder ("Proponent A"). On November 20, 2006, the
Corporation received a proposal and supporting statement ("Proposal B" and,
together with Proposal A, the "Proposals") for inclusion in the proxy materials
for the 2007 Annual Meeting from the SEIU Master Trust ("Proponent B" and,
together with Proponent A, the Proponents). Proposal A and Proposal B are
attached hereto as Exhibit A and Exhibit B, respectively. The Corporation hereby
requests confirmation that the staff of the Division of Corporation Finance (the
"Division") will not recommend enforcement action if the Corporation omits
Proposal B from the proxy materials for the 2007 Annual Meeting for the reasons
set forth herein.
GENERAL
The 2007 Annual Meeting is scheduled to be held on April 25, 2007. The
Corporation intends to file its definitive proxy materials with the Securities
and Exchange Commission (the "Commission") on or about March 19, 2007 and to
commence mailing those materials to its stockholders on or about such date.
Pursuant to Rule 14a-8(j) promulgated under the Securities Exchange Act of 1934,
as amended (the "Exchange Act"), enclosed are:
1. Six copies of this letter, which includes an explanation of why the
Corporation believes that it may exclude the Proposal; and
2. Six copies of the Proposals.
A copy of this letter is also being sent to Proponent B as notice of the
Corporation's intent to omit Proposal B from the proxy materials for the 2007
Annual Meeting.
SUMMARY OF PROPOSALS
Proposal A (To be included in the proxy materials for the 2007 Annual Meeting):
"RESOLVED, shareholders ask our board of directors to amend our bylaws to give
holders of at least 10% to 25% of the outstanding common stock the power to call
a special shareholder meeting."
Proposal B:
"RESOLVED, that shareholders of Bank of America Corporation ("BofA") urge the
board of directors to amend the bylaws to allow holders of 25% or fewer of the
outstanding shares of common stock to call a special meeting of shareholders."
REASON FOR EXCLUSION OF PROPOSAL B
The Corporation believes that Proposal B may be properly omitted from the proxy
materials for the 2007 Annual Meeting pursuant to Rule 14a-8(i)(11) because it
substantially duplicates another proposal previously submitted to the
Corporation by Proponent A that will be included in the proxy materials for the
2007 Annual Meeting.
Rule 14a-8(i)(11) permits the exclusion from the Corporation's proxy materials
of stockholder proposals that substantially duplicate another proposal
previously submitted by another proponent that will be included in the
Corporation's proxy materials for the same meeting. The Corporation intends to
include Proposal A in its proxy materials for the 2007 Annual Meeting. Proposals
do not need to be identical to be excluded pursuant to Rule 14a-8(i)(11). The
Division consistently has concluded that proposals may be excluded because they
are "substantially duplicative" when such proposals have the same "principal
thrust" or "principal focus," notwithstanding that such proposals may differ as
to terms and scope. See, Metromedia International Group, Inc. (March 27, 2001)
("Metromedia"); Time Warner Inc. (March 3, 2006) ("Time Warner"); American Power Conversion Corporation (March 29, 2002) ("American Power"); and UAL Corporation
(January 22, 2002) ("UAL"). As discussed below, in each of the foregoing
no-action letters, the Division concurred with the subject company's
characterization of the proposals as substantially duplicative under Rule
14a-8(i)(11) because the subject matter of the proposals was the same, despite
differences in wording, specificity and breadth.
As is the case in this request, in Metromedia, two shareholder proposals sought
to amend the company's governing documents to provide shareholders the ability
to call special meetings. The first proposal requested that Metromedia's board
of directors amend the company's "certificate of incorporation to allow
stockholders to call special meetings of the company's stockholders and to take
action by written consent." The second proposal requested that Metromedia "amend
the Company's by-laws to require the Chairman or Vice Chairman of the board of
directors of the Company to call special meetings of the Company's stockholders
when so requested in writing by any stockholder or trust, group or other
combination of stockholders of the Company collectively owning no less than
1,500,000 shares of the Company's common stock." Notwithstanding the proponent's
arguments to the contrary, the Division concurred with Metromedia's
characterization of the second proposal as substantially similar to the first,
despite the second proposal's greater detail and variations.
In Time Warner, two shareholder proposals sought to amend the corporation's
governing documents to remove the supermajority voting provisions. The first
proposal recommended that Time Warner's board of directors "take each step
necessary for a simple majority vote to apply on each issue that can be subject
to shareholder vote to the greatest extent possible." The first proposal also
stated that it was "focused on precluding voting requirements higher than
approximately 51% wherever practicable." The second proposal also urged the Time
Warner's board of directors amend specific sections of the company's certificate
of incorporation and bylaws to "remove the 80% of the outstanding shares voting
requirement for shareowners to amend the Company's bylaws." The Division
concurred with Time Warner's characterization of the second proposal as
substantially similar to the first, despite the second proposal's greater detail
and differing means to accomplish the same goal.
In American Power, two shareholder proposals sought to increase the number of
independent directors serving on the board of directors. The first proposal
requested "that the board adopt a policy to nominate director candidates such
that, if elected, a substantial majority of directors would be independent, and
if sufficient independent directors are elected, to appoint entirely independent
audit, compensation and governance/nominating committees. The second proposal
requested that the "board of directors set a goal of establishing a board of
directors with at least two-thirds of its members being independent directors."
The Division concurred with American Power's characterization of the second
proposal as substantially similar to the first, despite the second proposal's
greater detail and differing standards of measurement ("substantial majority"
versus "two-thirds").
In UAL, two shareholder proposals sought to require the corporation to obtain
shareholder approval for airline acquisitions. The first proposal requested that
UAL's board of directors amend the company's certificate of incorporation to
"provide that airline acquisitions, which have been approved by a Board of
Directors vote, also be approved by a stockholder vote." The second proposal
also requested that UAL's board of directors amend the company's certificate of
incorporation to "provide that airline acquisitions, which have been approved by
a Board of Directors vote, also be approved by a stockholder vote." However, the
second proposal also included a definitional term that would require stockholder
vote only "where the value of the transaction exceeds five percent of the
consolidated total assets of the corporation and its subsidiaries as reported in
its most recent audited financial statements." The Division concurred with UAL's
characterization of the second proposal as substantially similar to the first,
despite the second proposal's greater detail and five percent threshold.
The Corporation believes that Proposal B is properly excludable from the proxy
materials for the 2007 Annual Meeting under Rule 14a-8(i)(11). As noted above,
Proposal A asks the board of directors to amend the bylaws to give holders of at
least 10% to 25% of the outstanding common stock the power to call a special
shareholder meeting. Similarly, Proposal B urges the board of directors to amend
the bylaws to allow holders of 25% or fewer of the outstanding shares of common
stock to call a special meeting of shareholders. While not identical, there is
obvious and significant overlap similarity between the Proposals. In addition,
the supporting statement for both Proposals make similar arguments. Although
Proposal A and Proposal B are not identical in terms and scope, the Corporation
believes that Proposal A and Proposal B clearly have an identical "principal
focus" or "principal thrust." Both Proposal A and Proposal B request same
thingan amendment to the bylaws to enable stockholders to call special
meetings.
In addition, the Corporation believes the inclusion of both Proposal A and
Proposal B in the Corporation's proxy materials for the 2007 Annual Meeting
would be confusing to stockholders and, if both Proposals were approved by
stockholders, could result in alternative and inconsistent obligations being
imposed on the Corporation in order to satisfy the requirements of each of the
Proposals. The Corporation should not be required to include multiple proposals
concerning the ability to call special meetings of stockholders because, if each
were approved, the Board of Directors would have no way of knowing which
disclosure approach the stockholders prefer, nor would the Board of Directors be
able to fully implement each Proposal due to the potential for inconsistent or
conflicting provisions. Although their implementation is somewhat different, it
is clear that the core issues of Proposal A and Proposal B are substantially the
sameamending the bylaws to enable stockholders to call special meetings.
As noted above, the Corporation intends to include Proposal A in its proxy
materials for the 2007 Annual Meeting. Therefore, pursuant to Rule 14a-8(i)(11)
and consistent with the Division's interpretation of the rule in Metromedia,
Time Warner, American Power and UAL, Proposal B may be excluded therefrom
because it is substantially duplicative of Proposal A, which was previously
submitted and will be included in the Corporation's proxy materials for 2007
Annual Meeting.
CONCLUSION
On the basis of the foregoing, the Corporation respectfully requests the
concurrence of the Division that Proposal B may be excluded from the
Corporation's proxy materials for the 2007 Annual Meeting. Based on the
Corporation's timetable for the 2007 Annual Meeting, a response from the
Division by February 3, 2007 would be of great assistance.
If you have any questions or would like any additional information regarding the
foregoing, please do not hesitate to contact the undersigned at 704-386-9036.
Please acknowledge receipt of this letter by stamping and returning the enclosed
receipt copy of this letter. Thank you for your prompt attention to this matter.
Very truly yours,
/s/
Kenneth L. Wagner
Associate General Counsel
cc: William J. Mostyn III
SEIU Master Trust
[INQUIRY LETTER]
Ray T. Chevedden
5965 S. Citrus Ave.
Los Angeles, CA 90043
Mr. Kenneth D. Lewis
Chairman
Bank of America Corporation (BAC)
Bank of America Corporate Center Fl 18
100 N Tryon St
Charlotte NC 28255
Ph: 704-386-5972
Rule 14a-8 Proposal
Dear Mr. Lewis,
This Rule 14a-8 proposal is respectfully submitted in support of the long-term
performance of our company. This proposal is submitted for the next annual
shareholder meeting. Rule 14a-8 requirements are intended to be met including
the continuous ownership of the required stock value until after the date of the
respective shareholder meeting and presentation of the shareholder proposal.
This submitted format, with the shareholder-supplied emphasis, is intended to be
used for definitive proxy publication. This is the proxy for John Chevedden
and/or his designee to act on my behalf in shareholder matters, including this
Rule 14a-8 proposal for the forthcoming shareholder meeting before, during and
after the forthcoming shareholder meeting. Please direct all future
communication to John Chevedden at:
2215 Nelson Ave., No. 205
Redondo Beach, CA 90278
T: 310-371-7872
olmsted7p (at) earthlink.net
(In the interest of saving company expenses please communicate via email.)
Your consideration and the consideration of the Board of Directors is
appreciated in support of the long-term performance of our company. Please
acknowledge receipt of this proposal by email.
Sincerely,
/s/
Ray T. Chevedden
Ray T. Chevedden and Veronica G. Chevedden Family Trust 050490
Shareholder
cc: William J.. Mostyn III
Corporate Secretary
PH: 704-386-1621
FX: 704-386-1670
PH: 704-386-8486
FX: 704-386-6699
F: 704-386-9330
[APPENDIX1]
[Rule 14a-8 Proposal, November 7, 2006]
3 - Special Shareholder Meetings
RESOLVED, shareholders ask our board of directors to amend our bylaws to give
holders of at least 10% to 25% of the outstanding common stock the power to call
a special shareholder meeting.
Ray T. Chevedden, 5965 S. Citrus Ave., Los Angeles, Calif. 90043 sponsors this
proposal.
Currently, shareholders at some companies can take formal action at the annual
meeting of shareholders or call a special shareholders' meeting or take action
by written consent in lieu of a meeting. Limiting shareholders to acting at the
annual meeting at Bank of America gives the board and management too much
control over the timing of shareholder action.
Shareholders should have the ability, within reasonable limits, to call a
special meeting when they think a matter is sufficiently important to merit
expeditious consideration. Shareholder control over timing is especially
important in the context of a major acquisition or restructuring, when events
unfold quickly and issues may become moot by the next annual meeting.
Thus this proposal asks our board to amend our bylaws to establish a process by
which holders of 10% to 25% of our outstanding common shares may demand that a
special meeting be called. The corporate laws of many states (though not
Delaware, where our company is incorporated) provide that holders of only 10% of
shares may call a special meeting, absent a contrary provision in the charter or
bylaws. Accordingly, a 10% to 25% threshold strikes a reasonable balance between
enhancing shareholder rights and avoiding excessive distraction at our company.
Prominent institutional investors and organizations support allowing
shareholders to call a special meeting. Fidelity, Vanguard, American Century and
Massachusetts Financial Services are among the mutual fund companies supporting
a shareholder right to call a special meeting. The proxy voting guidelines of
many public employee pension funds, including the Connecticut Retirement Plans,
the New York City Employees Retirement System and the Los Angeles County
Employees Retirement Association, also favor preserving this right. Governance
ratings services, such as The Corporate Library and Governance Metrics
International, take special meeting rights into account when assigning company
ratings.
This topic also won 65% support of JPMorgan Chase & Co. (JPM) shareholders at
the 2006 JPM annual meeting.
Special Shareholder Meetings Yes on 3
Notes:
The above format is requested for publication without re-editing or
re-formatting.
The company is requested to assign a proposal number (represented by "3" above)
based on the chronological order in which proposals are submitted. The requested
designation of "3" or higher number allows for ratification of auditors to be
item 2.
This proposal is believed to conform with Staff Legal Bulletin No. 14B (CF),
September 15, 2004 including:
Accordingly, going forward, we believe that it would not be appropriate for
companies to exclude supporting statement language and/or an entire proposal in
reliance on rule 14a-8(i)(3) in the following circumstances:
the company objects to factual assertions because they are not supported;
the company objects to factual assertions that, while not materially false or
misleading, may be disputed or countered;
the company objects to factual assertions because those assertions may be
interpreted by shareholders in a manner that is unfavorable to the company, its
directors, or its officers; and/or
the company objects to statements because they represent the opinion of the
shareholder proponent or a referenced source, but the statements are not
identified specifically as such.
See also: Sun Microsystems, Inc. (July 21, 2005).
Please note that the title of the proposal is part of the argument in favor of
the proposal. In the interest of clarity and to avoid confusion the title of
this and each other ballot item is requested to be consistent throughout all the
proxy materials.
Please advise if there is any typographical question.
Stock will be held until after the annual meeting and the proposal will be
presented at the annual meeting.
Please acknowledge this proposal by email within 14-days and advise the most
convenient fax number and email address for the Corporate Secretary's office.
[INQUIRY LETTER]
November 17, 2006
William J. Mostyn III
Deputy General Counsel and Corporate Secretary
Bank of America Corporation
101 South Tryon Street
NC1-002-29-01
Charlotte, NC 28255
Dear Mr. Mostyn:
On behalf of the SEIU Master Trust ("the Trust"), I write to give notice that,
pursuant to the 2006 proxy statement of Bank of America Corp. (the "Company"),
the Trust intends to present the attached proposal (the "Proposal") at the 2007
annual meeting of shareholders (the "Annual Meeting"). The Trust requests that
the Company include the Proposal in the Company's proxy statement for the Annual
Meeting. The Trust has owned the requisite number of Bank of America shares for
the requisite time period. The Trust intends to hold these shares through the
date on which the Annual Meeting is held.
The Proposal is attached. I represent that the Trust or its agent intends to
appear in person or by proxy at the Annual Meeting to present the Proposal. I
declare that the Trust has no "material interest" other than that believed to be
shared by stockholders of the Company generally. Please contact me at
(202)730-7051 if you have any questions.
Sincerely,
/s/
Steve Abrecht
Executive Director of Benefit Funds
[APPENDIX2]
Shareholders' Right to Call Special Meetings
RESOLVED, that shareholders of Bank of America Corporation ("BofA") urge the
board of directors to amend the bylaws to allow holders of 25% or fewer of the
outstanding shares of common stock to call a special meeting of shareholders.
SUPPORTING STATEMENT
Currently, BofA shareholders can take formal action only at the annual meeting
of shareholders, or a special shareholders' meeting called by the board, board
chairman, CEO or president, because shareholders do not have the power to call a
special meeting. Shareholders may take action by written consent in lieu of a
meeting only if every share consents, which in a company of BofA's size and
dispersed shareholdings is impractical. In our opinion, prohibiting
shareholder-called special meetings and requiring unanimous written consent
gives management too much control over the timing of shareholder action.
Shareholders should have the ability, within reasonable limits, to call a
special meeting when they think a matter is sufficiently important to merit
expeditious consideration. Shareholder control over timing is especially
important, we think, in the context of a major acquisition or restructuring,
when events unfold quickly and issues may become moot before the next annual
meeting.
For those reasons, this proposal asks BofA's board to amend the bylaws to
establish a process by which holders of 25% or fewer of BofA's outstanding
common shares may demand that a special meeting be called. The corporate laws of
many states (though not Delaware, where BofA is incorporated) provide that
holders of only 10% of shares may call a special meeting, absent a contrary
provision in the charter or bylaws. Accordingly, we view a 25% threshold as
striking a reasonable balance between enhancing shareholder rights and avoiding
excessive distraction and cost to the company.
Prominent institutional investors and organizations advocate allowing
shareholders to call a special meeting. Fidelity, Vanguard, American Century and
Massachusetts Financial Services are among the mutual fund companies supporting
shareholders' right to call a special meeting. The proxy voting guidelines of
many public employee pension funds, including the Connecticut Retirement Plans
and Trust Funds, the New York City Employees Retirement System and the Los
Angeles County Employees Retirement Association, also favor preserving this
right. Governance ratings services The Corporate Library and Governance Metrics
International take special meeting rights into account when assigning governance
ratings.
We urge shareholders to vote for this proposal.
[INQUIRY LETTER]
December 22, 2006
By Facsimile and Overnight Delivery
Securities and Exchange Commission
Office of Chief Counsel
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Re: Stockholder Proposal Submitted by SEIU Master Trust
Ladies and Gentlemen:
By letter dated December 5, 2006, Bank of America Corporation (the
"Corporation") requested confirmation that the staff of the Division of
Corporation Finance (the "Division") would not recommend enforcement action if
the Corporation omitted a proposal and supporting statement (the "Proposal")
submitted by the SEIU Master Trust (the "Proponent") for inclusion in the proxy
materials for the 2007 Annual Meeting.
I am writing to notify you that the Proponent has formally withdrawn the
Proposal as evidenced by the attached letter dated December 19, 2006.
Accordingly, the Corporation would like to withdraw its request from
consideration by the Division.
We appreciate the attention that you have given to this matter. If you have any
questions or would like additional information regarding the foregoing, please
do not hesitate to contact the undersigned at 704-386-9036.
Best regards,
/s/
Kenneth L. Wagner
Associate General Counsel
cc: William J. Mostyn III
SEIU Master Trust
[INQUIRY LETTER]
December 19, 2006
William J. Mostyn III
Deputy General Counsel and Corporate Secretary
Bank of America Corporation
101 South Tryon Street
NC1-002-29-01
Charlotte, NC 28255
Via Email: William.mostyn@bankofamerica.com
Dear Mr. Mostyn:
This letter memorializes the agreement between Bank of America (the "Company")
and the SEIU Master Trust (the "Trust") regarding the withdrawal of a
shareholder proposal (the "Proposal") submitted to Bank of America on
shareholders' ability to call a special meeting, filed on November 17, 2006.
The Trust recognizes that another shareholder, Ray Chevedden, has filed a
similar resolution to that of the Trust. The intent of our fellow shareholder's
proposal seems very similar to our own, and therefore, we would be willing to
withdraw the resolution filed last month. We do, however, look forward to a
response from Bank of America regarding your intentions to address this
shareholder issue, and look forward to the Company's favorable response in
granting shareholders the right to call a special meeting under certain
circumstances. The Trust has also received email correspondence between the
Company and Ray Chevedden's representative, asserting that the Company will not
challenge Chevedden's proposal this year, regarding shareholders' ability to
call a special meeting.
Very truly yours,
/s/
Steve Abrecht
Executive Director of Benefit Funds
SA:TR:bh
cc: Tracey Rembert, SEIU Capital Stewardship Program
cc: Kenneth L. Wagner, Associate General Counsel
Kenneth.wagner@bankofamerica.com and Fax: 704-719-0843
[INQUIRY LETTER]
December 28, 2006
Kenneth L. Wagner
Associate General Counsel
Bank of America Corporation
NC1-002-29-01
101 S. Tryon Street
Charlotte, NC 28255
Re: Bank of America Corporation
Dear Mr. Wagner:
This is in regard to your letter dated December 22, 2006 concerning the
shareholder proposal submitted by SEIU Master Trust for inclusion in Bank of
America's proxy materials for its upcoming annual meeting of security holders.
Your letter indicates that the proponent has withdrawn the proposal, and that
Bank of America therefore withdraws its December 5, 2006 request for a no-action
letter from the Division. Because the matter is now moot, we will have no
further comment.
Sincerely,
/s/
Ted Yu
Special Counsel
cc: Steve Abrecht
Executive Director of Benefit Funds
SEIU Master Trust
1313 L Street, NW
Washington, DC 20005
[INQUIRY LETTER]
December 22, 2006
By Facsimile and Overnight Delivery
Securities and Exchange Commission
Office of Chief Counsel
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Re: Stockholder Proposal Submitted by SEIU Master Trust
Ladies and Gentlemen:
By letter dated December 5, 2006, Bank of America Corporation (the
"Corporation") requested confirmation that the staff of the Division of
Corporation Finance (the "Division") would not recommend enforcement action if
the Corporation omitted a proposal and supporting statement (the "Proposal")
submitted by the SEIU Master Trust (the "Proponent") for inclusion in the proxy
materials for the 2007 Annual Meeting.
I am writing to notify you that the Proponent has formally withdrawn the
Proposal as evidenced by the attached letter dated December 19, 2006.
Accordingly, the Corporation would like to withdraw its request from
consideration by the Division.
We appreciate the attention that you have given to this matter. If you have any
questions or would like additional information regarding the foregoing, please
do not hesitate to contact the undersigned at 704-386-9036.
Best regards,
/s/
Kenneth L. Wagner
Associate General Counsel
cc: William J. Mostyn III
SEIU Master Trust
[INQUIRY LETTER]
December 19, 2006
William J. Mostyn III
Deputy General Counsel and Corporate Secretary
Bank of America Corporation
101 South Tryon Street
NC1-002-29-01
Charlotte, NC 28255
Via Email: William.mostyn@bankofamerica.com
Dear Mr. Mostyn:
This letter memorializes the agreement between Bank of America (the "Company")
and the SEIU Master Trust (the "Trust") regarding the withdrawal of a
shareholder proposal (the "Proposal") submitted to Bank of America on
shareholders' ability to call a special meeting, filed on November 17, 2006.
The Trust recognizes that another shareholder, Ray Chevedden, has filed a
similar resolution to that of the Trust. The intent of our fellow shareholder's
proposal seems very similar to our own, and therefore, we would be willing to
withdraw the resolution filed last month. We do, however, look forward to a
response from Bank of America regarding your intentions to address this
shareholder issue, and look forward to the Company's favorable response in
granting shareholders the right to call a special meeting under certain
circumstances. The Trust has also received email correspondence between the
Company and Ray Chevedden's representative, asserting that the Company will not
challenge Chevedden's proposal this year, regarding shareholders' ability to
call a special meeting.
Very truly yours,
/s/
Steve Abrecht
Executive Director of Benefit Funds
SA:TR:bh
cc: Tracey Rembert, SEIU Capital Stewardship Program
cc: Kenneth L. Wagner, Associate General Counsel
Kenneth.wagner@bankofamerica.com and Fax: 704-719-0843
[STAFF REPLY LETTER]
December 28, 2006
Kenneth L. Wagner
Associate General Counsel
Bank of America Corporation
NC1-002-29-01
101 S. Tryon Street
Charlotte, NC 28255
Re: Bank of America Corporation
Dear Mr. Wagner:
This is in regard to your letter dated December 22, 2006 concerning the
shareholder proposal submitted by SEIU Master Trust for inclusion in Bank of
America's proxy materials for its upcoming annual meeting of security holders.
Your letter indicates that the proponent has withdrawn the proposal, and that
Bank of America therefore withdraws its December 5, 2006 request for a no-action
letter from the Division. Because the matter is now moot, we will have no
further comment.
Sincerely,
/s/
Ted Yu
Special Counsel
cc: Steve Abrecht
Executive Director of Benefit Funds
SEIU Master Trust
1313 L Street, NW
Washington, DC 20005
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