Subject: File No. 4-637
From: Martin J. Fry
Affiliation: Private Investor

September 11, 2014

Mr. Brent J. Fields, Secretary
Securities and Exchange Commission
100 F Street, Northeast
Washington, D.C. 20549
Re: File Number 4-637.

Dear Mr. Fields:

As an American who is one of the more than 50 million Americans who participate in 401(k) retirement savings plans and who has invested more than 50% of my savings in US stocks I am concerned with how the corporations I invest in are spending corporate funds on political activities. A company actively participating in political campaigns is a high risk endeavor with few tangible benefits for the investor and exposes investors us to investment risks which are difficult to evaluate and understand due to the limited amount of information companies proved to their investors concerning these campaigns.

I write in support of a petition by the Committee on Disclosure of Corporate Political Spending, File Number 4-637. In Citizens United v. FEC the US Supreme Court noted that shareowners could “determine whether their corporation’s political speech advances the corporation’s interest in making profits” and could discipline directors and executives who use corporate resources inconsistently with shareowner interests.

However, unless shareowners can easily access information about a company’s political speech and expenditures we will be unable to know whether such speech “advances the corporation’s interest in making profits” and will be unable to discipline directors and executives. The rulemaking sought by the petitioners would address that issue by giving shareowners the information we need to hold the managers and directors of our companies accountable.

Surely, three years and more than a million comments later, it is time for the SEC to act.

Sincerely,

Martin J Fry