Subject: File No. 4-637
From: Sam Daniel

November 27, 2012

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.


The Supreme Court looked at corporations as if they were a group of like-minded individuals banded together in a common cause. In fact, 99.9% of all corporations are composed of people working for a salary, who may or may not share the same political beliefs. Rank and file workers have no little or no meaningful input to the CEO and Board of Directors, and can have no impact on corporate decisions.

The Citizens United decision held that corporations are people. I hold that people should be held accountable for their decisions and actions. If a CEO and Board of Directors are going to spend corporate money to support political candidates, I have the right as a stockholder to know how much is spent and on which candidates. The easiest way to do that is to make sure the people and the media have access to the information.

I believe it would not be out of bounds to say that such corporate decisions could not and should not be made without a vote of the shareholders, if CEOs and BoDs are supposed to be representing shareholder interests.

Thank you for considering my comments.