Subject: File No. S7-42-10
From: Larry S Dohrs
Affiliation: Vice President, Newground Social Investment

March 1, 2011

March 1, 2011

Elizabeth M. Murphy
Securities and Exchange Commission (SEC)
100 F Street, NE
Washington, DC 20549-1090

Re: File No. S7-42-10 - Disclosure of Payments by Resource Extraction Issuers

Dr. Ms. Murphy,

I am Larry Dohrs, Vice President of Newground Social Investment, a money management firm based in Seattle, Washington. I write informed by many years of experience in assisting clients to achieve their financial goals in a manner consistent with their social and environmental concerns.

The mandated disclosure of payments by resource extraction companies is the most important reform that Newground has had the opportunity to address in our comments to the SEC. We see it as critical for investors for several reasons, and wish to make the following points:

1. Disclosure of payments under Section 1504 of the Dodd-Frank Act (now Section 13(q) of the Exchange Act) is clearly and unequivocally of material importance to investors. These disclosures will provide investors and investment managers important insights into the political risks facing the companies they research, and in which they may invest. Up to the present, companies have refused to provide detail on the flow of shareholder dollars to foreign governments and entities to shareholders themselves. Let us never forget that shareholders are the owners of the companies, and that these are shareholder dollars we are talking about. The obvious materiality of these payments has been brought home recently in the Middle East and North Africa where, through Wikileaks, populations have been shocked to learn of the wealth and corruption of their leaders and leaders families, with attendant instability and disruption. Clearly, if payment information had been disclosed on an ongoing basis, gradual reform would most likely have taken place, and the costs of disruption minimized. We are talking real money here.

2. Disclosure of payments must be filed with rather than furnished to the SEC. The disclosure that is required by Section 13(q) is fundamentally similar to existing disclosures that have long been required under Section 13 of the Exchange Act, and therefore must be handled in a fundamentally similar manner.

3. It is critical that the Commission avoid allowing exemptions to Section 13(q). As investors, we have been repeatedly frustrated by (in our own experience) oil and gas companies making false claims regarding their contracts and dubious requirements that payments to foreign entities not be disclosed. If a simple clause in a contract allows companies to avoid disclosure, this is a loophole that every company could and would drive an oil tanker through. Do not allow anyone an exemption, and keep all companies on a level playing field.

4. Please recall that the overwhelming majority of major oil firms will be covered under this rule, and people the world over, US investors in particular, will benefit from uniform application of Section 13(q). The rule only requires that tax and royalty information, and does not require the disclosure of commercial terms of contracts, so the required disclosures do not create a competitive disadvantage for companies that comply.

We appreciate the opportunity to comment on this matter. We reiterate that this is of the highest material importance to us as investors seeking critical information upon which to base investment decisions for ourselves and for clients of Newground Social Investment.


Larry S. Dohrs