March 21, 2012
General:
Comment on File Number 4-637
Interpretive:
Corporations are owned by their shareholders.
As owners, shareholders are entitled to know what political contributions are being made by the corporation. But the Annual Report and other information provided to the shareholders rarely - if ever - contain this information, and certainly do not provide the details of when, how much, and for what, that would enable the shareholders to provide feedback on these expenditures. The information could also influence the decisions of investors to buy or sell the corporation's stock.
Public corporations will provide this information, in the requisite detail, only if the SEC requires them to do so.
Any claim that reporting this information would impose an onerous burden on corporations is disingenuous. The officers of the Corporation surely have this information already compiled, for accounting purposes at least.