April 28, 2012
Dear members of the Securities and Exchange Commission:
I am a shareholder/investor in publicly-traded corporations, and a company's spending on political campaigns is a fact that I consider to be material in deciding whether to purchase its shares.
I want to know, among other things, whether a corporation is spending more money trying to influence political campaigns, or on lobbying to relax regulations, than on research to improve its products or services, since I consider this material to whether the company will be a good investment over the longer term.
I also prefer to invest in companies that are "good citizens," at least in the sense that they are NOT spending earnings to promote policies likely to result in degradation of the environment, unfair exploitation of workers, etc. This is material to my own welfare and, again, in my opinion, to the long-term sustainability of the company's business, and therefore to my decision as to whether to invest in the company.
I urge the SEC to issue a rule requiring publicly traded corporations to make detailed disclosure of all their political spending, including which candidates are being promoted or attacked.
It's equally important that disclosures should be posted promptly on an SEC website and that there be provisions for enforcement and severe penalties for violation of the regulations.
Thank you for considering my comment.
Sincerely,
Carolyn Sortor