Subject: Comment on File Number 4-637

February 4, 2013

Dear Members of the Securities and Exchange Commission:

As an employee of one corporation and a stockholder in many, I am unable to learn anything about the contributions, lobbying and perhaps even bribes that corporate officers authorize on my behalf.

If these activities were all beneficial to the stockholder, one might consider them as normal corporate governance. All too many of the budget items and rules that are embedded into unrelated bills in the dead of night benefit the corporate officers at the expense of the stockholders.

Why should the commonly accepted accounting rules represent the cost of political activities as a black element in the P&L with no further drilldown merely to be bundled with other promotional activities?

Besides stockholder rights, there is an issue of voter rights. Voters take a candidates benefactors into consideration and need a standardized reporting structure for comparison.

A politician who is about to grant an extraordinary benefit to a corporation, his staff and all of the lobbyists can currently trade on non-public knowledge. While such activity should properly be criminalized, forcing the insiders to disclose money transfers would help competing investors infer the state of play.

So I strongly support the SEC issuing a rule in the near future that would require publicly traded corporations to publicly disclose all their spending on political activities.

Thank you for considering my comment.


Robert Cruder