April 11, 2012

Subject: Comment on File Number 4-637


My real name is Harvey W. Bogard Jr. Skip Bogard is a nickname.

I am a financial supporter of CREW, and they have suggested that I write to you and ask for a ruling from the SEC.

I would very much appreciate it if you would issue a rule requiring publicly traded corporations to publicly disclose all their political spending.

Of course, if you try to issue this rule, companies along with Fox News will scream that this is an undo hardship and an extra cost to business that will hurt their bottom line.

I have a MBA from Duke University Fuqua School of Business; with that shared, let me add that I can't think of any legitimate business reason why this information shouldn't be made public. Additionally, this would not cause an undo hardship on a company to calculate this number. THEY KNOW EXACTLY HOW MUCH THEY SPEND-- AM QUITE CONFIDENT. And I am quite confident that 99% of company accountants have this number calculated by computer and stored in one T-account (one budget account). All they have to do is publish the number.

So, I would appreciate it if you would issue this rule. It is good for the country...but not so good for TV advertising. Please try to ignore any lobby by advertising firms in your decision. Thank you very much.


Harvey W. Bogard Jr.