Subject: Comment on File Number 4-637

November 26, 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.

In addition, part of the Court's thinking was that political contributions would be public knowledge, and that this would serve as a check on corruption of the electoral process. We are already seeing how untraceable outside money is used to influence state and local elections, sometimes (as in Montana) in violation of state laws, because without disclosure it is impossible to prevent or prosecute.

Thank you for considering my comment.

Sincerely,

Walter Kirkconnell