Subject: File No. 4-637

November 18, 2015

Speaker Paul Ryan
Office of the Speaker
H-204 The Capitol
Washington, DC 20515
Phone: (202) 225-4000
Fax: (202) 225-5117

The Hon. Nancy Pelosi
House Minority Leader
United States Capitol
Washington, DC 20515
E-mail:  http://www.democraticwhip.gov/content/email-whip

Re: Address Need for the Corporate Political Spending Disclosure Rule

Dear Speaker Ryan and House Minority Leader Pelosi:

With U.S. Securities and Exchange Commission (SEC) Chair Mary Jo White testifying today before the U.S. House Financial Services Committee, acknowledged should be the strong demand for a rule requiring disclosure of corporate political spending.

To enact its mandate to protect investors, the SEC needs to require material disclosures of critical business information for investors, and react quickly to the changing practices and priorities of corporate entities. An obvious example of this need is the increased amount of spending in politics by corporate entities that has come in the wake of the U.S. Supreme Court’s 2010 Citizens United decision.

A petition to the SEC for rulemaking on disclosure of this spending has received more than 1.2 million supportive comments – a record for the agency and inclusive of a bipartisan group of former SEC chairs and commissioners, state treasurers, major pension funds and others.

Without adequate disclosure of corporate political spending, shareholders and investors have little means to hold corporate directors accountable and to safeguard their investments. Voluntary disclosure has led to a patchwork of information that makes it impossible for investors to manage, and potentially mitigate, the full range of risks presented by corporate political spending.

Corporate political spending choices may diverge from a company’s stated values or policies and embroil the company in hot-button issues. Investors have a right to know and understand if their invested money is going to support or oppose candidates or political issues.”

The SEC must protect investors and heed this request for action and move forward with the rule. 
Thank you for the opportunity to bring these remarks to your attention.
Yours sincerely,
Robert E. Rutkowski
cc:
Chairperson Mary Jo White
SEC Headquarters
100 F Street, NE
Washington, DC 20549
(202) 942-8088
e-mail: rule-comments@sec.gov