Date:    12/17/97  10:01 AM

Subject: File No. S7-26-97 / Arthur Karlin

        The ideas supporting the bills full disclosure for H.R. 944 and
democracy for H.R. 945 are widely advocated and often considered good in 
themselves.  And while I do not wish to test these here, there are some 
difficulties with the proposal legislation.  
        The demoratic basis for H.R. 945 is clear but how much democracy is 50
to 60 percent owned by institutions?  Stock owned by mutual funds and pension 
plans are particularly troublesome since the fund managers vote the share not 
the beneficial interest holders.  In this case one set of representative is 
substituted for another with no real decrease in the gap between vote and 
decision.
        In assessing the impact of the two bills, especially H.R. 945. 
Knowledge of the current distribution of charitable gifts would be helpful. 
That legislation might result in widely recognized charities garnering an 
increasing share of corporate giving.  
        What portion of public corporation giving is solicited by charitable
organizations?  Such a procedure does allow narrowly focused charities to vie 
for gifts based on detailed proposals for the use of funds.  H.R. 945 may reduce
the viability of this procedure with negative consequences for the diversity of 
charities and program oversight by donors.
        Are a significant portion of corporate gift now directed to religiously,
ethic or race based charities?  Would H.R. 945 result in a shift in that 
direction and toward a more sectarian outcome?  In this regard, it would be 
helpful to study the matching gift programs of public corporations to see how 
they currently handle gifts to religious, ethnic, and race based charitable 
organizations and modify the proposed legislation, if necessary.
        It is not clear exactly what is meant by charitable contributions.  If a
broad definition is to be used it would include all gifts to charity not limited
to those deductible under the United States (U.S.) Income Tax.  Thus, services 
provided charities through say loaned employees should be included as should any
gifts to foreign charities by a hrough the airwaves or in real audio over the 
internet and it broadcasts programs produced for a national audience?
     
FROM:  Arthur Karlin
        School of Business and Management
        University of Arkansas at Pine Bluff 
        Pine Bluff, AR  71603
        karlin_a@vx4500.uapb.edu