Subject: File No. 265-28
From: Dr. Ed and Harriet Griffith
Affiliation: New Progressive Alliance

March 7, 2014

March 7, 2014

Subj: 4 Year Strategic Plan for the SEC

The New Progressive Alliance at urges the SEC to include a plan for disclosure of corporate political contributions. While any political contributions by a public corporation should be known to all, it would still be of great benefit even if the disclosure be only to the stockholders.

Disclosure of political expenditures shows a companys values, plans and objectives as well as exposing risks not otherwise apparent to investors. Shareholders can also more easily make investments consistent with their values.

Both citizens and corporations now agree that secret corporate political spending is bad for business. Half of SP 100 companies make their political contributions transparent and require their directors to oversee the process. Three-quarters of business executives polled by the Corporate Reform Coalition support the SEC rule to require corporations to disclose their political spending. These corporations understand that transparency and oversight act as a necessary counterbalance to the inherent legal, reputation and brand risks that come with involvement in the political process. Shareholder proposals have been an important driver of enhanced transparency and oversight.

Corporate contributions used to be regulated and now they are not even disclosed. Corporations are free to secretly contribute to political causes in contrast to unions which face strict disclosure requirements. Unlike the SEC requirements for corporations, unions must submit regular reports on their political contributions. More than $6 billion was spent on last years elections nationwide, over double the amount spent in 2000. That is not a good trend, especially when one considers the full extent of the money spent may not have been disclosed.

The SEC should not overlook the three-quarters of a million public comments that it has already received urging disclosure of corporate political contributions. The huge number a record for SEC comments clearly indicate investors, academics and the general public recognize the importance of more disclosure of corporate political activity.


Ed and Harriet Griffith
New Progressive Alliance