Subject: File No. 4-637
From: Richard Fedder

November 6, 2013

SEC Comment file 4-637

Dear Comment file 4-637,

I am deeply concerned about the influence of corporate money on our electoral process.

In particular, I am appalled that, because of the Supreme Court's ruling in Citizens United v. Federal Election Commission, publicly traded corporations can spend investor's money on political activity in secret.

Corporations are not really people.  This is a legal fiction.  And a bad one at that.  If you go back to the Santa Clara RR case in the 1880's that set the first precedent, it was a tax case with the rr's claiming they were taxed unfairly.  I am a lawyer and have read the whole case.  It never said corporations are equal to people for taxing persons.  There was no constitutional ruling in the case.  The Court just said Santa Clara's tax was wrong based upon local law.

The reason that matters is because there has never been a legitimate rationalization for this Corporations are people fiction.  Corporations have no soul, no conscience, no motive to look out for the welfare fo the people when making a political contribution.  If a corporation knew for example that smoking causes cancer, or lead paint causes retardation, they would still not report it to the public.  Because their only legitimate motive is profit.  A corporation is a piece of paper, a license from the govt -- that's all.

Therefore, a corporation should not be entitled to the privacy rights of anonymity that a person might have.

In particular, a corporation is not responsible for political positions, advocated with corporate money.  If one good person in management of a corporation has a fit of conscience that he puts ahead of profits, he can and probably will be removed.

The only way to hold a corporation accountable for their political activities is by forcing them to reveal themselves.  Then at least, consumers of their products can protest.

I am writing to urge the Securities and Exchange Commission to issue a rule requiring publicly traded corporations to publicly disclose all their political spending.

Both shareholders and the public must be fully informed as to how much the corporation spends on politics and which candidates are being promoted or attacked. Disclosures should be posted promptly on the SEC's web site.

Thank you for considering my comment.


Richard Fedder