Subject: Comment on File Number 4-637

April 28, 2012

Dear members of the Securities and Exchange Commission:

I am writing to urge the SEC to issue a rule requiring publicly traded corporations to publicly disclose all their political spending.

Both shareholders and the public must be fully informed as to how much the corporation spends on politics and which candidates are being promoted or attacked. Disclosures should be posted promptly on the SEC's web site.

It is unfortunate that this request must be citizen initiated and not come directly from you the SEC. It should be self evident to you that who private companies choose to support in the political realm, and by how much, should be a matter of public record.
These are not private citizens exercising their rights of political behavior. Rather, they are legal entities with no a priori rights when it comes to how they choose to behave politically to promote their private agendas and interests.

It is therefore imperative for the body politic to know how such entities choose to conduct themselves to promote their private interests. This should be self evident to you.

In addition, you should not seek refuge behind the illusion that it is up to the shareholders of the companies to decide if the money spent to promote their private interests should be public information. Shareholders have vested interests in this matter, they are not acting in a purely public manner, directly, but indirectly through the company's directors who decide such things. This is therefore not an action taken by a citizen but by a legal entity.

This entity enjoys rights by its nature but they do not extend to a free pass in shielding from the public how the entity chooses to influence political decision making to defend or promote its private agenda.

This is private behavior with public import that principles of good government requires citizens to know about.

Unfortunately this elementary principle of democratic organization of societies is something that has been completely lost in the last 20 years as too much of the public sphere has been bought out and subsequently completely overwhelmed by private interests acting independently of the public realm.

Now would be an excellent occasion to attempt to bring some reasonable balance between private and public interests for the sake of this very fragile democracy.

I therefore demand that you enforce the principle that the public's right to know about companies' private political decisions outweighs "privacy rights" of private entities.

Thank you for considering these remarks.


ben lichtin