February 19, 2013
Ms. Elizabeth M. Murphy
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-1090
Re: File No. 4-659, Petition for Rulemaking Under Section 13(f) of the Securities Exchange Act of 1934
On behalf of RadioShack Corporation, a company listed on the NYSE, I am writing in support of the above referenced petition for rulemaking filed by NYSE Euronext, the Society of Corporate Secretaries and Governance Professionals and the National Investor Relations Institute. We join them in urging the U.S. Securities and Exchange Commission (the "Commission") to amend the beneficial ownership reporting rules under Section 13(f) of the Securities Exchange Act of 1934 in order to shorten the reporting deadline under paragraph (a)(1) of Rule 13f-1 from 45 days to two business days after the end of the calendar quarter. We would further support the a filing frequency at the end of each calendar month with a two business day reporting deadline.
As a public company, we take very seriously the need for effective communication with our shareholders, both to understand their views and to enable us to convey our beliefs regarding what courses of action are important to our company and all its constituents, including our shareholders. In today's world of ever-faster turnover of institutional positions, it is more important than ever that we have more current information regarding the identity of our institutional shareholders. The Commission recognizes that it is important to have public disclosure of institutional investor holdings. Given the advances in recordkeeping technology in the more than 30 years since the reporting requirement was adopted, there does not seem to be any justification for the existing deadline under which an institutional investment manager can make an investment on the first day of the quarter and delay disclosure of that investment for more than four months.
Thank you for the opportunity to comment on this important issue.
Vice President, Investor Relations