Subject: File No. 4-567
From: Greg Elin
Affiliation: Chief Data Architect, Sunlight Foundation

October 22, 2008

Large publicly traded companies have a significant presence in society beyond active investors. The notion of a good corporate citizen has long since entered the mainstream and annual reports. Consumers and investor increasingly think in terms of socio-economic values when making purchasing and investing decisions.

Accordingly, a true 21st Century Disclosure Initiative and Company File would include Corporate and Social Responsibility (aka CSR) information to make important social, environmental, and other non-financial information available in structured formats along side more traditional financials. Already corporations are providing this information on their websites and in their annual reports.

While it is difficult for the SEC to regulate the full range of CSR data, it is possible to define initial information all publicly-traded companies should be required to support. This required information would reflect factual and materially relevant interactions with and findings by governmental authorities.

As part of defining a Company File for the 21st Century, the following information Corporate and Social Responsibility information can and should be included as it is materially relevant to socially-aware investors and consumers, and citizens:

(1) Any company receiving government subsidies--local, state or federal--should be required to report this information as individual line items representing the corporations measure of value of such subsidies. For example, the federal government transfers hundreds of billions of dollars to the private sector in the forms of direct payments, tax credits and abatement, and loan guarantees. Publicly traded companies should be required to report explicit information on these benefits received from taxpayers. (See for examples of reporting of government contracts as a model.)

(2) Government misconduct citations, findings, and penalties should be reported so investors can evaluate the priorities of management of individual companies and establish a sense of what is common within an industry. Such disclosure will become even more critical to investors and citizens as concern over environmental impact of industry grows. (See as example of federal misconduct findings.)

(3) Summary of monies spent in politically-related activities such as lobbying and travel for elected officials and civil servants at federal and state levels, as well as contributions made from corporate treasuries to 527 and 501(c)4 organizations for political purposes. Although various federal laws require this information to be disclosed, the SEC has an interest in seeing this information disclosed in one place as part of a company file in order to provide a full picture of a companies activities.