Subject: Comment on File Number 4-637

November 26, 2012

Dear members of the Securities and Exchange Commission:

Firms make many investments to maximize their profits. I don't really care what they choose to do within the law. I'd like to hope for better, but that's the system we have.

Most S&P 100 firms find it beneficial to disclose their spending on political campaigns. Good for them. Shareholders can choose whether such reporting matters or not. Fine.

Is it right to require all firms to disclose all political contributions in light of the Citizens United decision? How are these contributions different from other investments a firm might make?

Legally, I have no idea on what basis the SEC can require such disclosures. But as both a shareholder, a citizen, and an Economist, I would like to see such disclosures.

Why? Because an investment in a candidate or in lobbying in particular is different than an investment in new machinery for a firm. It is an investment that affects everyone who takes part in the democratic process. Lobbying expenditures are through the roof over the last decade, and many scholars argue that these expenditures distort regulatory processes.

Elections are noisy moments in our history when the people speak. The great danger we face is that mega-donor megaphones will drown out the people's voices, if not before the election then after votes are counted.

Shareholders and the public have a right to know about such shouting, not only because it can affect firm value (perhaps l, the direction of the economy at large, and the well-being of our citizens generally.

Thank you for considering my comment.


R. J. Briggs