From: Gary Duck
Sent: March 19, 2016
To: rule-comments@sec.gov
Subject: RE: Disclosure Effectiveness Review

The SEC and its commissioners should continue to work on a rule requiring political disclosure from public companies, in the interests of their shareholders. Businesses should not be empowered to use backdoor political channels like nonprofits or associations to do their political bidding, and shareholders have a right to know how executives are using company resources for political purposes — especially if those purposes are against shareholders' interests.

While it is true shareholders can file resolutions to do this, you well know the proxies are almost always voted in favor of the board position regardless of how much good the shareholder resolution would be for all shareholders. No, it will take the SEC to play gatekeeper on corporate political spending. And the rules need to be written in such a way that the spending is very clear and detailed. Not summarized into some obscure total in the back pages of a long filing.

In fact, political spending may well need to be a whole new form to be filed on a regular basis by corporations. That will allow interested shareholders to find the information without having to be experts in the arcane ways of myriad SEC filings.

Gary Duck