Subject: Comment on File Number 4-637

April 17, 2012

Money politics. Crony capitalism. K-Street commandos. Compliant legislators. We have heard and seen it all before. But as bad as it was, it was never this huge nor this blatant.

Those of us who are not utter fools realize the current "set of rules" threaten to bring what remains of our increasingly laughable "democracy" swiftly and surely to an end. We are rapidly approaching the CEO nirvana of government of the corporation, by the corporation and for the corporation.

Needless to say, it would be an enormous understatement to say I am deeply concerned about the continuing and rapidly increasing influence of corporate money on our electoral process.

In particular, I am appalled that not only can unlimited amounts be spent by corporations on elections but because of the Supreme Court's ruling in Citizens United v. Federal Election Commission, that publicly traded corporations can spend investor's money on political activity in secret. This is totally absurd. And dangerous.

Accordingly, I am writing to urge the Securities and Exchange Commission do something very simple. Just issue a rule requiring all publicly traded corporations to publicly disclose all their political spending. Investors, both current and potential, need to know.

Both shareholders and the public should 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 and they should be included in the corporate prospectus and quarterly financial reporting.

Otherwise, how can shareholders know whether corporate managers are obtaining good value for their expenditures? Particularly if the payoff is not immediate and it is not clear exactly what services were purchased?

How else will the shareholders know that key votes and compliance of the most strategically situated politicians were guaranteed? Simple faith?

Good corporate governance, and the SEC's presumed role therein, should not be denied for lack of information. Even if it involves revealing the intimate, proprietary secrets of how to successfully and profitably deal with Washington.

Thank you for considering my comment.

Robert Rucker

Santa Fe, NM