Subject: Comment on File Number 4-637

February 9, 2012

Securities and Exchange Comm.

Dear Securities and Exchange Comm.,

As a citizen, a consumer, and an individual stockholder, I believe that I should be informed about any political investments that are made as a result of the Supreme Courtís ruling in Citizens United v. Federal Election Commission. Investors should have the right to this information to judge whether the board of directors is acting in the best interests of shareholders or in their own self-interest.

Mandating such disclosure will likely result in additional explanations from companies to shareholders to provide justification for these contributions. Permitting companies to withhold this information is not in the best interest of shareholders since it permits directors to substitute personal political bias or self-interest for actions that are in the best interest of the company. Shareholder oversight is crucial to avoid such abuse.

I have read and support the petition from the Committee on Disclosure of Corporate Political Spending calling for new rules regarding the disclosure of corporate political speech in the form of monetary expenditures.

I most strongly urge the SEC to issue a rule (or rules) requiring that all publicly traded corporations immediately disclose political contributions of any form and that the SEC make such disclosures immediately available on their website. I want to emphasize that the immediacy of such disclosures and their availability to the public would be critical to the effectiveness of such a rule. The rules should also require disclosure of any indirect political contributions made through intermediate entities.

Thank you for your consideration in this matter.


Paul Krueger, Ph.D.