Subject: Comment on File Number 4-637

January 13, 2013

Securities and Exchange Comm.

Dear Securities and Exchange Comm.,

I am writing to urge you to consider making disclosure of social and political expenditures mandatory. The Supreme Court in its Citizens United ruling relied on and assumed transparency of such expenditures. Unfortunately, their ruling did not require it; that requirement must emanate from your office.

An efficient market requires transparency, yet corporations are spending ever increasing amounts of money on political causes with decreasing transparency. This situation can and should be corrected.

Milton Friedman wrote about such expenditures as "socialism" and an abomination, the spending by corporate managers of other people's money. When conservatives and progressives are allied on an issue, the time is right for the SEC to act.

I am an accounting professor and a CPA and I believe such disclosure is necessary for shareholders and the public to better understand the behavior of large corporations.

Thank you for considering my comment.


Sue Ravenscroft