Subject: Comment on File Number 4-637

January 19, 2012

Securities and Exchange Comm.

Dear Securities and Exchange Comm.,

I'm writing to urge the commission's prompt approval of rules requiring public disclosure of political spending by publicly-held companies. Disclosure is vital to the SEC's responsibility to ensure that investors have the information they need to make sound decisions about when and where to put their money. Shareholders also have a right to know how companies in their investment portfolios are investing that money, particularly when the spending falls outside the company's normal business activity.

This idea ought to be a complete no brainer and should not require a moment of hesitation before deciding that this must become official SEC policy. If individuals are obliged to detail their contributions, then so should corporations, now that five supreme court justices declared that they have the rights of individuals re campaign contributions. They have the right and they should also be forced to assume the responsibilities that go with that right. That is what I mean by a complete no brainer. You should force this policy at all private corporations to which the citizens united decision (unfortunately) applies.

Thank you for considering my comment.


ben lichtin