April 28, 2012
Dear members of the Securities and Exchange Commission:
To emphasize the importance of requiring corporations to publicly disclose ALL of their political spending, allow me to present a local example.
I am a farmer who wishes to build a dairy barn on a corner of my property that is downwind from my house, thus sparing me the smell. But this site is too close to the road, is upwind from the village elementary school, and drains into a creek home to protected species. So the zoning board won't let me build it.
But I know my other neighbor, who has similar issues and desires, wishes to build the same structure for the same reasons, but is prohibited for all the same reasons. My neighbor has a charismatic son who could, if placed on the zoning board, help tip the vote in our favor.
The problem is that everybody in the county knows this. So we decide to pool our funds to launch a big campaign to get my neighbor's slick son elected. We plan to mount the biggest campaign our county has ever seen, but it is a problem because the incumbent my neighbor's son would be running against is really popular. The incumbent is a steadfast advocate of children's health and environmental protection, and who has been most vocally opposed to me and my neighbor building our dairy barns. This kid-loving, tree-hugging board member has done a lot of good for our township, it is true, but they've gone too far by hurting me and my neighbor's dairy business.
So in our campaign, we get the guy who is the best scripture reader in our church to do a radio ad that talks about how EVERYONE'S freedom is endangered by the incumbent's love of red tape, and that my neighbor's son is for freedom, not big government. We hire a bunch of local high schoolers to go door to door, talking to other farmers who know how tough it is about how the government is getting in the way of our dairy business, and if they don't do something by voting for my neighbor's son, then the government is going to come after them, too.
The people with kids in the elementary school, and the people at the local prairie research station are harder to win over, but we keep plying them with mailings, phone calls, and ads anyway.
Lots of people come up and thank my neighbors son for taking a stand for their freedom. They think he's so nice for putting so much of his time, energy, and resources into looking out for them. There's of course people who you can never win over, but anyway, as long as they don't know how much money we put into this process, we think we'll come out of this looking pretty good and able to build our dairy barns wherever we want. Of course, it would be much harder for us if people knew how much we paid to influence their opinions. But we had to put in a lot of money to slowly convince people to vote against the interests of children and local ecology, and to vote against a popular incumbent who obviously has the communities' interest at heart. If they ever find out, we'd probably be run out of town. So it is best for us to keep this secret.
This little hypothetical example should make the following perfectly clear:
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.
You know which decision is the right thing to do. This is a democracy, not a corporatocracy, and you must, in times like these, recall who it is that you serve in a democracy. You serve the public, and corporations are not 'the public.'
Thank you for considering my comment.
Julie Michelle Klinger