May 6, 2012

Subject: Comment on File Number 4-637

Dear Sir or Madam,

I am writing to urge the Securities and Exchange Commission 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 a corporation spends on politics and which candidates they are promoting or attacking. Disclosures should be posted promptly on the SEC’s web site.

I am retired from the position indicated in my sig block, but prior to working for the Church I was an attorney, first in Alaska and then in Idaho. In between I did mediation for a living. My legal education was with Harvard Law School.

A healthy political disclosure system should mean that people with an axe to grind should not be able to endeavor to manipulate the election or the electorate through a front group. There are many organizations on the political scene with fine, public-spirited names, that are in fact a front organization for a person or group with a very narrow economic interest and purview. That should not be possible to do in secret. If we are going to adopt an advocated-for position, we should at least know who with what sort of interests in the matter is advocating the position, as that can shed light on the proposal itself. We need to see the book, not just the cover.

The rule should cover corporations, partnerships, and LLC's, and any like organization, and direct or indirect donations, or many layered donations. Thus if X gives to Y gives to Z, no matter how many steps, all steps should be visible.

Thank you for considering my comment.

† Peace, De Colores!

Ted Burton, LL.B., C.P.M., M.P.S.,
Pastoral Associate, retired, Sacred Heart Church
Lapwai, Nez Perce Indian Reservation, Idaho.
"Ke koná híisemtuks hiwséetu wéet'u máwa héenek'e tuuqélenu!"