March 27, 2014
Elizabeth M. Murphy, Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609
Dear Ms. Murphy:
A little over four years ago, Citizens United v. FEC opened a floodgate of corporate funds onto the U.S. election process. Two and a half years ago, the Committee on Disclosure of Corporate Political Spending submitted a petition, now File Number 4-637, asking that the FEC require publically held corporations to disclose any substantial sums spent on direct or indirect political "speech." And in their decision, the Supreme Court argued that shareholders could monitor and correct any inappropriate spending not directly related to a company's business and in furtherance of profits.
And here we are, still with no such requirement, and in fact Chairman Mary Jo White has removed the petition from consideration in 2014. So how are we, stockholders in many companies, supposed to exercise our responsibilities envisioned by the Court? These are publically owned companies, allowed to engage in non-disclosed or poorly disclosed political spending-spending which may more reflect the whims and beliefs of CEOs and Directors, rather than to further clearly defined corporate goals. Why shouldn't such spending be publically disclosed?
We urge the SEC to bring the petition back to its agenda, and to quickly enact such regulations. While many companies have voluntarily adopted such disclosures, many others have not. We can only suspect that companies that have chosen secretiveness might find disclosure uncomfortable, or outright embarrassing, and find that their shareholders might strongly disapprove of such spending.
Thanks, Joel & Jean McCormack