Subject: File No. S7-25-15
From: Patric Barry
Affiliation: CEO, Tiger International Resources Inc

December 19, 2015

This reporting requirement is redundant to the obligations of company's auditors, and is another example of government recklessness and waste of time and paper.
The proclaimed reason for requiring payment reporting is to stop payment of bribes and graft. There are already laws in place to prevent such payments by US, Canadian, Australian, British companies, and auditors are charged with the responsibility of detecting such payments and are obliged to report them. So, requiring companies to report payments to governments and government employed individuals is redundant and time wasting.
Companies must employ people to address compliance issues, and this is expensive. Companies must raise capital, yet so much of it goes on frivolous compliance issues like this proposal.
To require companies to report this information is an unnecessary burden on the companies, and what is the SEC going to do with the reporting anyway? It is useless information. It takes time, effort, money to provide the information, and government time, effort, money to review it. And for what benefit? None
If a company is going to break existing laws by paying a bribe it surely won't voluntarily report it? Yet this proposed law requires that ALL payments be reported - typical payments by international mining company payments are license fees, taxes, royalties, all of which are required by the host country, so where is there benefit to the reporting company or to the SEC in generating the information in a format required by the SEC, with draconian penalties if the reporting company screws up?
Government seems to rely on income from penalties these days. The huge fines that are assessed against companies don't benefit wounded individuals who may have been defrauded, they benefit government, so government has the incentive to assess pernalties so as to provide employment for the inspectors. This proposed law is merely another gateway for government to meddle, to fine, and to take capital away from shareholders to the benefit of government.
The proposed law should not proceed.