April 28, 2012

Subject: Comment on File Number 4-637

Dear members of the Securities and Exchange Commission:

I am writing to urge the SEC to issue a rule requiring publicly traded corporations to publicly disclose all their political spending.

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.

One fact about corporate charters: public corporations are NOT chartered to spend on activities not involved in improving the profits or value to shareholders, except to comply with legal or ethical norms. Any money given to political campaigns or super PAC's, or spent directly on political advertising, is thus NOT A JUSTIFIABLE BUSINESS EXPENSE unless it is done to increase profits. BUT, if it IS DONE TO INCREASE PROFITS, then by definition it is CORRUPTION. Until such corruption is recognized by a future Supreme Court, there is at least the legal authority of the SEC to regulate PUBLIC corporations. This will let stockholders know that their dividends are being spent, and consumers know that what they pay for goods and services is being spent, for activities AGAINST the beliefs of those stockholder and consumers.

Thank you for considering my comment.


Allan Richardson