Subject: File No. S7-42-10 - Comment from Paul Ramshaw

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:

Section 78m(q)(2)(A) requires you to issue final rules that require each resource extraction issuer to disclose the designated types of payments to any foreign government (or foreign-government-owned or -controlled entity) or to the U.S. government. Your statutory obligation is clear. Please do not issue regs that lessen the obligations on the resource extraction issuers!

Paul Ramshaw