As the Securities and Exchange Commission and the U.S. Chamber of Commerce continue to battle it out in court over the independent chairman rule that requires 75% of a mutual fund's board, including its chairman, to be independent, a new study on the subject might surprise some in the industry.

In 2004, 78% of the directors at fund companies were independent, a survey of 1,500 directors overseeing 8,000 funds shows, according to The Wall Street Journal. But even 10 years ago, 71% of the directors at mutual fund boards were independent. That increased to 75% in 2002. The Investment Company Institute and the Independent Directors Council have conducted the survey every other year for the past 10 years.

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