Subject: File No. 4-637
From: Valerie Gardner

April 2, 2013

Even though the courts might choose to interpret corporations as persons for some legal interpretations, they are not people!  Rather, they are used by people for some legitimate and some not legitimate purposes.  I am therefore writing to urge the Securities and Exchange Commission to protect consumers from the misuse of corporate funds for improper purposes by issuing a rule requiring publicly traded corporations to publicly disclose all their political spending.  It is important that this illicit behavior be curbed as quickly as possible, so you should address this matter this year.

“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 attempting to thwart the will of the public. It is a scandal that money from publicly traded corporations – which belongs to investors – can be secretly spent to distort our democracy.  You need to act to prevent this abuse of corporate power in the hands of a few radical corporate leaders.

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.

Both shareholders and the public must be fully informed as to how much corporations spend on politics and which candidates are being promoted or attacked. Disclosures should be posted promptly on the SEC’s web site.

Thank you for considering my comment.

Valerie Gardner

Atherton, CA