Subject: Comment on File Number 4-637

January 13, 2013

Securities and Exchange Comm.

Dear Securities and Exchange Comm.,

My long held understanding of shareholders rights and responsibilities make it clear that the management of a publicly held corporation must provide with utmost clarity, its use of Corporate funds.

How can we know if an executive is playing golf or going on vacation or making a donation to his favorite cause...perhaps one in a family members name. It is a requirement that I prove my donations to charity, and this is my money! A Corporation and its management, must be completely transparent in its use of Company funds, there can be no ambiguity.

I write to urge the commissionís prompt approval of rules requiring public disclosure of political spending by publicly-held companies. Shareholders also have a right to know how companies in their investment portfolios are investing that money, particularly when the spending falls outside the companyís normal business activity.

Thank you for considering my comment.


Lee Kalish