Subject: Comment on File Number 4-637

March 21, 2012

It's the SEC's job to make sure disclosure with respect to publicly traded and owned companies takes place fully and transparently. Shareholders and potential shareholders are entitled to know how working capital and coprorate assets and wealth are being deployed, since they are trying to make informed judgments as to investments in these same corporations, and evaluate how they behave and make judgments in managing.

Please take this mandate seriously, and exercise it fully, on behalf of citizens, taxpayers, and investors.

As one aspect of that, I am deeply concerned about the expenditure of corporate money on our electoral process.

In particular, I am appalled that, because of the Supreme Court’s ruling in Citizens United v. Federal Election Commission, publicly traded corporations can spend investor’s money on political activity in secret.

I am writing to urge the Securities and Exchange Commission to issue a rule requiring publicly traded corporations to publicly disclose all their political spending.

Both shareholders and the public must be fully informed as to how much the corporation spends 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.

William Sharfman

New York, NY