Subject: File No. 4-637
From: Randall Rensch

April 24, 2013

TO: Securities and Exchange Commission

I have read and strongly support the petition to require public companies to disclose to shareholders the use of corporate resources for political activities.

This is not a political issue. It is a shareholder issue, and is fundamental to the operation of our governmental system as understood by the Supreme Court.

The following excerpt from the petition summarizes this point:

In particular, in its recent decision in Citizens United v. FEC, 21 the Court relied upon “[s]hareholder objections raised through the procedures of corporate democracy” as a means through which investors could monitor the use of corporate resources on political activities. “Shareholders,” the Court hoped, could “determine whether their corporation’s political speech advances the corporation’s interest in making profits,” and discipline directors and executives who use corporate resources for speech that is inconsistent with shareholder interests. For this mechanism to work, however, shareholders must have information about the company’s political speech; otherwise, shareholders are unable to know whether such speech “advances the corporation’s interest in making profits.”  [But absent disclosure,] shareholders are unable to hold directors and executives accountable when they spend corporate funds on politics in a way that departs from shareholder interests.

In contrast, this statement from US Chamber of Commerce (as summarized in the NY Times, 4/24/13) is disingenuous:

The Chamber believes that the funds expended by publicly traded companies for political and trade association engagement are immaterial to the company’s bottom line,” said Blair Holmes, a spokeswoman for the business group, who added that the advocates’ “apparent goal is to silence the business community by creating an atmosphere of intimidation under the cover of investor protection.”

If political contributions supposedly don’t matter to a company’s bottom line, why do they make them? All the more reason that shareholders should be informed.  I am a member of the “business community.”  If a company discloses a political stand and thus may be penalized in its marketplace, that is for the free market to decide.

Randall Rensch, investor