Subject: File No. 4-637
From: John Goodman

November 9, 2013

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 – and to do so this year.

Such a rule, to be truly effective, MUST mandate disclosure in a timely manner, which is to say, well before any election or vote in a local, state, or national legislature such a donation may be intended to influence. And that disclosure should be made at least to the Sec. of State in each state where political influence is being sought--if not in a more public manner--as well as to the shareholders of that corporation. Again, all of these disclosure should be mandated as happening long enough before the events they may seem to be intended to influence take place that the recipients of that information (voters, shareholders, or whomever) can let their views be known also prior to that decision.

“Dark money” groups that accept contributions from corporations, but are not required to publicly identify their corporate donors, spent millions of dollars during the 2012 elections. It is a scandal that money from publicly traded corporations – which belongs to investors – can be secretly spent to distort our democracy.

The Supreme Court’s ruling in Citizens United v. Federal Election Commission created the loophole that enables this secret spending, but the SEC has the authority to close it.

Both shareholders and the public must be fully informed as to how much corporations spend 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.

John Goodman

Garden Grove, CA