805,615 802, 200 740,300 701, 454 673, 726 670,220 654, 586 630, 320 579, 791 557, 500 Perc & Co., care of Trust Department Safekeeping Division, Northwestern National Bank of Minneapolis, Minneapolis, Minn.. 1,236,656 Cudd & Co., care of The Chase Manhattan Bank, P.O. Emp & Co., care of Trust Department, Harris Trust & Barnett & Co., care of Bankers Trust Co., Box 704, Stuart & Co., care of First National City Bank, 20 Carson & Co., care of Morgan Guaranty Trust Co., 928,863 GENERAL ELECTRIC COMPANY APRIL 3, 1972. DEAR SENATOR METCALF: In answer to your request of March 11 to Mr. Borch, we enclose a listing of the 30 largest share owners of record. You will appreciate that most of these are nominee accounts for banks, funds and other institutions. As you know, the American Society of Corporate Secretaries prints a nominee list which shows some of the institutions for which the nominees hold shares. We would have no information as to who the beneficial owners are of the shares held in nominee accounts. Very truly yours, GREGORY M. SHEEHAN, SHARE OWNER Accounts AS OF DECEMBER 18, 1971 551, 200 662, 174 Thomas & Co., care of First National City Bank, 20 Exchange Pl., New York, N. Y. Trude & Co., care of Continental Bank, Trust Securities Division, Lock Box 835, Chicago, Ill Ford Motor Co... 482, 500 643, 970 452, 640 642, 000 Way & Co... 443,789 629, 116 Carothers & Clark, care of Bank of Delaware, Box 1910, Wilmington, Del. Cuyler & Co.... 621, 100 A. A. Welsh & Co.. 402,100 616, 289 Sigler & Co., care of Manufacturers Hanover Trust Co., New York, N.Y. 386,956 602, 553 1 4,815,394 shares held for account of the Trustees of General Electric Savings and Security Trust. 2 Deposits in Central Certificate Service by participating institutions. As reported by Stock Clearing Corporation, this represents holdings of 188 participants. GENERAL MOTORS CORPORATION APRIL 12, 1972. DEAR SENATOR METCALF: Mr. Gerstenberg, who cur294,500 rently is out of the country on a business trip, has asked me to thank you for your letter of March 11 requesting information about the common stock and stockholders of General Motors Corporation. 294,400 285,300 Olen & Co., care of Trust Department, First National Bank of Chicago, 33 South Clark St., Chicago, Ill..... 283,520 1 This is the nominee for the Company's Savings and Stock Investment Plan for Salaried Employees. All these shares are held in trust for the benefit of participating employees. This is a stock clearing corporation established by the New York Stock Exchange. Treasury shares; cannot be voted. As of December 31, 1971, the corporation had issued 287,604,280 shares of common stock. Since there were 1,379,100 shares in our treasury, the number of shares outstanding on that date was 286,225,180. This information appears on pages 30 and 31 of the attached 1971 annual report for General Motors Corporation. You also requested a list of the top 30 stockholders in the corporation along with the amount of common stock held by each. It is our policy not to disclose specific information concerning individual stockholders, as such individuals or organizations may regard their holdings as a matter that is private to them. However, some generalized data regarding the owners of the corporation appears on page 26 of the annual report. This may be helpful to you. I am sure you will find much other useful information in the annual report. Also attached is a copy of a booklet, General Motors Policies and Progress, which I believe will be of interest to you.' Thank you for your interest in General Motors. ROBERT F. MAGILL, GENESCO MAY 5, 1972. DEAR SENATOR METCALF: Thank you for your letter of 2 May, 1972, requesting certain information concerning the voting stock and the principal stockholders of our company. At the date of our most recent stockholders meeting, 6 December 1971, the aggregate number of votes represented by all classes of voting stock was 14,191,948. There were approximately 49,000 holders of voting stock and we estimate that about 10,000 of these were employees of our company. Our company is unlike certain of the other corporations of which you have made similar requests in that many of our 30 top stockholders are individuals. We prefer not to disclose the holdings of these individuals, unless legally required to do so, because we feel this would be a breach of the privacy of the company-stockholder relationship. We appreciate the fact that you would not have made this request except in the public interest and we regret that our responsibilities to our individual stockholders prevent us from furnishing all the requested information. Sincerely, J. OWEN HOWELL, President. B. F. GOODRICH COMPANY MAY 12, 1972. DEAR SENATOR METCALF: Mr. Keener of our Company has referred to me your letter of May 2 in which you indicate that you would appreciate receiving a list of the thirty top stockholders of our Company, including the amount of common stock owned by each. We must inform you that we feel that the identity and stockholdings of our stockholders are confidential and we therefore cannot supply you with the list you request. As is apparently the case of the companies referred to in the excerpts from the April 25th Congressional Record which you sent us, substantially all of our large stock holders of record are in fact not the beneficial owners but are nominee accounts in which the stock is actually owned by a great number of people. Respectfully yours, R. G. JETER, Vice President and General Counsel. Retained in committee files, GOODYEAR TIRE & RUBBER COMPANY DEAR SENATOR METCALF: Thank you for your letter of May 2, 1972, requesting certain information pertaining to the stockholder records of The Goodyear Tire & Rubber Company. You requested receiving a list of the thirty top stockholders of our company and the amount of common stock each holds. Under the general corporation law of the State of Ohio it is provided that any shareholder of a corporation, upon written demand stating the specific purpose thereof, shall have the right to examine in person or by agent or attorney, at any reasonable time and for any reasonable and proper purpose, the records of shareholders of the corporation. We deem our shareholder lists, and in particular the amount of common stock each such shareholder holds, to be private and confidential information between the shareholder and our corporation. Except for complying with a request which sets forth the specific purpose by a shareholder, in accordance with Ohio law, we are not in a position to disclose this information. With respect to your second request, for the total number of voting shares of common stock issued by our company, this information does appear in our company's annual report. As of December 31, 1971, the total number of outstanding voting shares of our common stock was 72,759,871. If we can be of further assistance to you in this matter, please let us know. Very truly yours, F. S. MYERS, Secretary. W. R. GRACE & CO. MAY 17, 1972. DEAR SENATOR METCALF: Receipt is acknowledged of your letter dated May 2, 1972, asking for a list of the thirty top stockholders of our company and the amount of common shares held by each, and requesting the total number of voting shares of our common stock. In response to the latter part of your request, please be advised that the total number of voting shares of our common stock, outstanding as of the end of 1971, was 25,204,526 shares. Concerning your request for a list of the thirty top stockholders of our company, I regret that we must respectfully decline to make a voluntary disclosure of this information to you. It is our policy not to disclose individual stock holdings of our stockholders to persons outside the company except when so required by law or regulation. This policy is based upon our belief that the relationship between the company and the stockholder is a private one and that public disclosure of such stock ownership would violate a confidential relationship. information in no way reflects upon your objectives in I am certain you appreciate that the withholding of this seeking the information. Our position is based solely upon what we believe to be our responsibility to our stockholders. Very truly yours, JOHN F. KELSEY, Vice President. GREYHOUND CORPORATION MAY 10, 1972. DEAR SENATOR METCALF: Your letter of May 2, 1972, concerning Greyhound stockholders was forwarded to me in Phoenix where our headquarters are now located. The Greyhound Corporation is considered to be a carrier subject to the Interstate Commerce Act, and as such files each year a list of its ten largest shareholders. Aside from this, we have in the past treated the shareholdings of any particular person as confidential information. I will, however, comply with your request upon the understanding that you will not place in the Congressional Record the number of shares held by any particular entity. Accordingly, there is enclosed a list of the 30 largest shareholders of The Greyhound Corporation as of March 17, 1972, which is the record date for our annual meeting. You will note that practically all of the large shareholders are brokerage houses holding as nominees. So far as we know, no one shareholder has a beneficial interest in more than 1 percent of Greyhound's outstanding stock. As of March 17, there were 40,478,504 common shares outstanding. Respectfully yours, GERALD H. TRAUTMAN, Chairman of the Board and Chief Executive Officer. EXCERPT FROM ANNUAL REPORT OF THE GREYHOUND CORPORATION TO THE ICC FOR THE YEAR ENDED DECEMBER 31, 1970MOTOR CARRIER ANNUAL REPORT FORM A sarily relevant to your request. We declined the prior request because of what we deem to be a fiduciary obligation to each of our stockholders to hold in confidence the fact that he is a stockholder of our corporation. That matter was litigated before the courts of Minnesota. The opinion dated November 24, 1969 of the Trial Court, the District Court for the Fourth Judicial District of Minnesota, and the opinion dated October 22, 1971, of the Minnesota Supreme Court both held that the requesting stockholder was not entitled to the stockholder list. Those courts stated that for a stockholder to be entitled to a disclosure of the names of other stockholders he must have a ditional relevance is the fact that the Delaware statute purpose germane to his interest as a stockholder. Of adprovides for the disclosure to a stockholder of a list of stockholders only if the purpose of the request is reasonably related to such person's interest as a stockholder. We have noted from the enclosures with your letter that the lists of stockholders submitted to you by certain other corporations have been printed in the Congressional Record and in view of the foregoing this causes us some concern in view of what we deem to be our responsibility to our stockholders. However, if, notwithstanding the foregoing, you still desire to obtain the list of our 30 top stockholders, upon your request we will be glad to draft an inquiry to each of them and furnish you with the name of each such stockholder who consents to the disclosure of his name. MY DEAR SENATOR METCALF: We have your letter of May 2, addressed to Edward B. Hinman, former chief executive officer of this Company. The only stock of this Company entitled to general voting rights is the common stock. At the close of business on February 15, 1972, the record date for our 1972 shareholders' meeting, there were 44,519,220 common shares outstanding. To comply with your request for a list of the 30 top stockholders and the amount of common stock each holds would be contrary to a long-standing policy of this Company. This policy is based on a belief that the shareholders have a right to expect the management to treat their shareholdings as confidential information. I trust you will understand our position. ARTHUR R. TAYLOR, JUNE 1, 1972. DEAR SENATOR: This refers to your request for certain information as to our major shareholders, which was addressed to Mr. Gordon Edwards, our former Chief Executive Officer, who has now retired. Mr. W. O. Beers is now Chairman and President of Kraftco. As requested, I am enclosing a list showing the thirty top stockholders of Kraftco Corporation and the number of shares of common stock held by each as of December 25, 1971, the end of our most recent fiscal year. As of that date there were 29,413,832 shares of Kraftco Corporation common stock outstanding. Very truly yours, Jos. L. CALVIN, Vice President and Secretary. LING-TEMCO-VOUGHT CORPORATION DEAR SENATOR METCALF: This is in reply to your letter of May 2, 1972, requesting information concerning the total number of shares of common stock of this Corporation and the names of the holders of the thirty largest amounts of such stock. As of March 20, 1972, there were issued and outstanding 7,369,667 shares of common stock, par value $0.50 of the Corporation. Although your letter refers only to voting shares of common stock I should also advise you that the Corporation has shares of other voting securities outstanding. We are unable, however, to respond to your request for the identity of the thirty stockholders of the Corporation holding the largest number of shares of common stock inasmuch as we regard this information as confidential and available only in accordance with the laws of the State of Delaware pursuant to which the Corporation was incor1972, as far as is known to management, no person held porated. I can advise you, however, that as of March 20, of record or beneficially 10 percent or more of the outstanding securities of the Corporation except that Cede & Co. on that date was the record owner of 2,880,701 shares of common stock of the Corporation. The Corporation is advised that Cede & Co. acts as nominee for Stock Clearing Corporation, 44 Broad Street, New York, New York, which fvrnishes a central stock clearing service to numerous brokerage firms. I trust that the information stated herein will be of assistance to you and that you will understand our 30 HIGHEST HOLDERS OF KRAFTCO CORP. STOCK (TAKING NOMINEE position, which we believe is proper, with respect to your request for the names of stockholders. Very truly yours, HOLDINGS INTO ACCOUNT) AS OF DECEMBER 25, 1971 PAUL THAYER, Chairman of the Board, and Chief Executive Officer. 323, 409 313, 257 302, 919 Number Holder of shares State Street Bank & Trust Co., Boston, Mass.. 330, 245 Girard Trust Bank, Philadelphia, Pa.. The Cleveland Trust Co., Cleveland, Ohio.. The First Pennsylvania Banking & Trust, Philadelphia, Pa.... LITTON INDUSTRIES MAY 5, 1972. DEAR SENATOR METCALF: I am responding to your letter of May 2, 1972, to Roy L. Ash, President of Litton Industries, Inc.' Pursuant to your request, I enclose a list of the 30 largest holders of voting stock of Litton Industries, Inc. and the number of shares owned by each. Six of the 30 holders are listed as non-institutional holders, 5 of which are private individuals and 1 is a private foundation. We do not feel free to divulge these names without the consent of the individuals involved. We assume you are not interested in the identity of individual shareholders. If, however, you do wish to request the names of these individuals, please let us know and we will request their consent. Excluding the 6 non-institutional holders, treasury 151, 018 stock, and Litton stock held in the Litton Employees Pension Trust, the institutional holdings amount to 38.2 percent of the total voting stock. As of April 1, 1972, the total number of voting shares was 37,158,203, consisting of four classes of shares, each 125, 652 having one vote per share. 124, 630 121, 553 118, 349 7,847, 128 Yours sincerely, GLEN MCDANIEL, Chairman of the Executive Committee. Dean & Davis, care of Wilmington Trust Co., Wilmington Del... 210, 358 Salkeld & Co., care Bankers Trust Co., Box 704, Church Street, Station, New York, N. Y. 204, 855 187, 449 177, 758 175, 133 162, 433 16, 917, 546 1 Nominee for Litton's Pension Plan. The shares are held in trust for the benefit of participating employees. Treasury shares are not voted." LOCKHEED AIRCRAFT CORPORATION MAY 11, 1972. DEAR SENATOR METCALF: In a letter of May 2, you requested a list of the 30 top stockholders of our company and other share ownership data. I should like to respond most respectfully that we consider it the responsibility of the management of the company to protect share ownership data as being private, confidential information that should be divulged to other shareholders only when there is a proper companyconnected purpose." Perhaps providing the following information will be helpful to you. Lockheed had 11,358,610 shares of common stock outstanding as of March 31, 1972. It was held by 53,336 accounts of record, MINNESOTA MINING AND MANUFACTURING COMPANY MAY 4, 1972. DEAR SENATOR METCALF: This is with reference to your letter of 2 May, 1972, wherein you request certain stockholder information. This is to advise you that on March 23, 1972, the record date for the 1972 Annual Meeting, there were 56,319,549 shares of 3M common stock outstanding, each share being entitled to one vote. With respect to the list of the 30 top stockholders, we consider this information to be confidential. Under Delaware law, a stockholder may examine the corporation's stock ledger if the purpose of the examination is reasonably related to such person's interest as a stockholder. If you are willing to be more specific as to the purpose for which this information is requested, we would give consideration to contacting the top 30 stockholders with a view to obtaining their consent to make this disclosure. I hope you will understand the position we feel we must take on this matter. Yours very truly, ROBERT H. TUCKER, General Counsel. MONSANTO COMPANY JUNE 9, 1972. DEAR SENATOR METCALF: This will acknowledge receipt of your 2 May letter to Mr. Bock requesting a list of the 30 top stockholders of Monsanto and the amount of common stock each holds. |