From: Leahy for Senate on behalf of David Garland Sent: Tuesday, January 31, 2012 3:25 PM

Subject: Require disclosure of corporate spending in politics. 4-637

January 31, 2012

Securities and Exchange Commission

Dear Commission,

Please exercise your regulatory authority to require public disclosure of corporate political contributions.

In Minnesota, state law requires public disclosure, and the state law has considerably increased transparency to the public. It has likewise increased transparency to investors and stockholders, who have the need to know what the managements of their companies are doing. In 2011, shareholder resolutions occasioned by such disclosure resulted in the Target Corp. board reviewing and revising corporate guidelines for such expenditures.

But this is not something that works well on a state-by-state basis. Especially in the light of the Citizens United decision, there should be a national requirement for such disclosures. The CPA-Zicklin Index of Corporate Political Disclosure and Accountability shows that "disclosure is becoming a mainstream practice". It should be not only mainstream, but mandatory.


David Garland