Subject: File No. 4-637
From: David Morf

September 7, 2012

Dear Commissioners of the Securities and Exchange Commission:

I am writing to urge the Commission to issue rules under the 1933 and 1934 Acts requiring new and reporting issuers and publicly traded issuers to disclose publicly all their political and lobbying spending.

Both shareholders and the public must be fully informed as to how much the issuer spends on politics and lobbying, and which candidates and matters are being promoted or opposed. Disclosures should be posted promptly for current event and reporting-period spending as well as for year-to-date and prior years on the Commission's web site and also included in Current and Quarterly Reports and in Annual Reports to Shareholders including the MD&A. Such disclosures of the use of issuer resources should not be buried in footnotes.

Thank you for considering my comment.


David Morf