Subject: File No. 4-637
From: Thomas Laird

November 14, 2013

Honorable Chairperson of the SEC
Mary Jo White


Dear Chair White,

This letter is to urge you to immediately open an inquiry regarding political donations by publicly traded corporations, and whether it would be appropriate for the SEC to formulate new regulations in that regard. During that process I urge you to seek not only input from corporate executives but from the average shareholder as well.

How much money is being spent by publicly traded corporations on political donations in America, or abroad? To whom is it being given, by which corporations? Are these donations in the best interests of shareholders—or are they in the best interests of corporate executives and antithetical to the interests of the corporations and their shareholders? Is it true that the more money spent by corporations on political donations, the less money is available for profits for shareholders? If such donations are to be allowed what regulations are in place to insure that shareholders see a return on the cost of political donations? If there is no return on this cost, why is it an allowed cost? If shareholders do not know exactly how much money is being spent on this now hidden cost, and if they do not know what is the amount of return on this cost, how can they, as shareholders make informed purchase/sell decisions? Might it not be more appropriate for executives of publicly traded corporations to be banned from any and all contributions to elected officials, their campaigns, or to PAC’s seeking to sway the outcome of elections, if in fact there is no way to prove that such donations have any net positive impact on the bottom line of those corporations? What other expenses are corporations allowed to make, out of view of their shareholders, on which they cannot show a net positive impact to shareholders?

This black hole of corporate political donations is undermining shareholder confidence in the market and without transparency it has a detrimental impact on publicly traded securities, and in a broader sense on the course of American democracy itself.

At the very least there is a strong argument to be made that every corporation must publicly list the amount and recipient of every donation it makes—even if they are to be allowed by SEC regulation. Right now shareholders find it hard, if not impossible, to acquire that information. Since the Securities Exchange Act of 1934 authorizes the SEC to write regulations that are "necessary or appropriate in the public interest or for the protection of investors," and since the press estimates that corporate donations during the last election cycle exceeded 1 Billion US$, clearly it is long past time for the SEC to formulate new regulation in this regard.

If I am wrong in my belief that the SEC has not yet instigated an internal investigation in this regard, please advise me what steps are now underway. If such an investigation is underway, please advise me when you expect to issue new regulations.


Thomas Laird