Subject: File No. S7-42-10 - Comment from Joseph Kraus

February 10, 2012

Dear SEC Commissioners,

Please do not give in to industry pressures on Section 1504 of the Dodd-Frank Act (the Cardin-Lugar Amendment) - and make sure that ALL companies are covered, every country and every project gets reported, and loopholes that would allow large sums of money to go unreported are closed.

My Comment:

The SEC should not be cowed by the oil companies' suggestions that strong rules could put them into conflict with host country laws. Oil companies have provided no credible evidence that any such laws currently exist, and allowing exemptions would create an incentive for countries to create laws to avoid the disclosure of payment information. The SEC's mandate is to design a strong US law, NOT to look into a looking glass to divine whether or not the US law could someday come into conflict with the laws of other countries.

Joseph Kraus