U.S. Securities & Exchange Commission
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U.S. Securities and Exchange Commission

The following Letter Type E, or variations thereof, was submitted by individuals or entities.

Letter Type E:

We, the undersigned, represent a diverse community of concerned citizens. We are elected officials, shareholders, institutional investors, consumers, community organizers, nonprofit leaders, and much more. Whereas we have many differences among us, we share a view that openness is a core hallmark of a strong democracy and we, the undersigned, are all united in support of the pending petition before the SEC to require public companies to disclose their political spending to shareholders.

According to recent research by the Sustainable Investments Institute and the IRRC Institute, voluntary corporate disclosure of political spending remains limited, with only 20 percent of S&P 500 companies reporting on how they spent shareowners' money. In addition, only 38 companies out of the entire S&P 500 mention independent expenditures, such as Super PAC contributions, as part of their policies on corporate political spending. We cannot and should not be left in the dark about the use of corporate treasury dollars in our elections.

Now is the time to act. Two years ago, the Supreme Court's ruling in Citizens United v Federal Election Commission opened the floodgates on political spending in this country. With more than $4 billion in total spending, the 2010 election was the most expensive midterm election in U.S. history. This year's Presidential election will undoubtedly break records on election spending once again - with millions of dollars in undisclosed spending being channeled through anonymous contributions to trade associations, 501c4 organizations and eventually Super PACs.

We ask that the Securities and Exchange Commission act quickly to consider the proposed rule on disclosure of corporate political spending. Transparency in corporate political spending is in the best interests of investors, companies and the general public, and we strongly believe that the Securities and Exchange Commission is the most appropriate agency to require such disclosure.





Modified: 05/01/2012