Subject: File No. 4-637
From: Allan Richardson

November 8, 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.

“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.  There is a fundamental difference between individual PAC contributions and the use of funds from a corporate treasury.

When someone gives $5, $10, or $10 million dollars to a PAC, the donor is a WILLING, AWARE donor.  When a customer pays for a product or service, the customer is UNWILLING and UNAWARE that the profit earned by the company will be donated to a political cause that may be AGAINST the customer's interest.  Likewise, when an investor invests in a company, that investor expects dividends to reflect the profit, less REASONABLE, BUSINESS-RELATED costs and investments: NOT donations to a political cause that may be OPPOSED by that stockholder.

In other words, political donations by corporate leaders are NOT the expression of THEIR free speech rights.  They are, rather, a sign of MISAPPROPRIATION OF SOMEONE ELSE'S MONEY.  Requiring these donations to be publicly acknowledged will expose what amounts to EMBEZZLEMENT of shareholder funds, so that shareholders and customers can take action to be reimbursed, and to get rid of those bad actors in corporate management.

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.

Allan Richardson