Subject: File No. S7-42-10
From: Horace Patterson

February 11, 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:

We have had a chance for decades to weigh in on corruption in developing countries for years and spoke about it quite often with conviction. Now it is time to put some teeth into the rules of engagement vis a vis how we regulate the behavior of companies that our government have oversight responsibilities over in conducting business internationally. Please release the rules for Section 1504 with no exemption and no loopholes.

Horace Patterson