Subject: File No. S7-42-10
From: Elizabeth Nadler

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:

Please, on Section 1504, follow the language of the law, not the demands of industry. It is unconscionable that the oil company lobbyists would pressure you in this way, but it will be the most egregious of acts if you give in to their demands. The strong rules of 1504 will really help the US take the leadership on transparency. Other countries will surely follow. The exemptions in Section 1504 will render the law ineffective - so what will be the point? I, along with many others are requesting that you do the right thing; release the rule for Section 1504 with NO EXEMPTIONS and NO LOOPHOLES. After the Wall Street debacle, the mortgage crisis and particularly pertinent to your purview, the mortgage-backed securities fraud, we must be seen as promoting transparency, not only in the US, but around the world. Our reputation and moral standing has already suffered enough, and many people were literally thrown into poverty. We cannot, in good conscience, allow our greed and negligence to force more Africans into the same situation. The numbers of Africans living in poverty in oil-rich countries is staggering. The US must not directly contribute to increasing those numbers.

Elizabeth Nadler