January 13, 2013
For the protection of investors and in the public interest, I am writing to urge the SEC to issue a rule requiring publicly traded domestic and foreign issuers, as well as registered investment management companies and broker/dealers, to timely and publicly disclose all their US political spending. I am writing to urge the Securities and Exchange Commission to act on this rule this year of 2013.
“Dark money” groups that accept contributions from corporations, but are not required to publicly identify their corporate donors, spent millions of dollars during the 2012 elections. It is a scandal that money from publicly traded corporations – which belongs to investors – can be secretly spent to distort our democracy.
The Supreme Court’s ruling in Citizens United v. Federal Election Commission created the loophole that enables this secret spending, but the SEC has the authority to close it.
To make the disclosure efficient and timely, I urge the Commission to add a box on the cover page of Form 8-K indicating that political disclosure information is being reported in Topical Category Section 6, currently unused, to enable easy identification by the public of the reporting of US political spending by domestic and foreign filers.
Shareholders and the public must be fully informed as to how much an issuer or regulated firm spends on politics including the amount and identity of any contribution bundling organization, and the amount, identity, and pro or con intent of such spending relative to each candidate and public initiative thereby being promoted or opposed.
Disclosures as proposed above in Section 6 of Form 8-K should be posted promptly and prominently on the SEC's web site. In this matter, "promptly" means not later than two calendar days after receipt by the SEC, and delivery and receipt must be accomplished by means of electronic filing not to exceed the four day filing requirement of Form 8-K.
Thank you for considering my comment.